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<!DOCTYPE html><html class=NEWSSTAND lang=en-US><head data-reactroot=""><title>ZINIO</title><link rel="icon" type="image/png" href="https://admin-project-assets.ziniopro.com/99/20190227144922-99-0.png"/><meta charSet="UTF-8"/><meta name="robots" content="noindex, nofollow"/><meta name="viewport" content="width=device-width, initial-scale=1, maximum-scale=3.0"/></head><body><h1>Zinio Legal Notices</h1> <ul> <li> <a href="#terms">Terms of Service</a> </li> <li> <a href="#policy">Privacy Policy</a> </li> <li> <a href="#refund">Refund Policy</a> </li> <li> <a href="#cookies">Cookies Policy</a> </li> <li> <a href="#california-appendix">Privacy Notice for California residents</a> </li> </ul> <a name="terms"></a> Terms of Service    Effective Date: September 24, 2019   Welcome to Zinio! Access to, and use of Zinio's website located at <a href="https://www.zinio.com">www.zinio.com</a> (the “Site”) and other Zinio services (together with access to, and use of the Site, the “Service”) are subject to the following Terms of Service (these “Terms”) and subject to our  <a href="https://www.zinio.com/legal/terms#policy">Privacy Policy</a>. Please read these Terms carefully. Creating an account with Zinio or otherwise accessing or using the Service will signify that you have read, understand, and agree to be bound by these Terms and to comply with all applicable laws and regulations. These Terms constitute a binding agreement between you and Zinio, LLC (“Zinio” or “we” or "our"). If you do not agree to these Terms, you may not use the Site or the Service. THESE TERMS CONTAIN WARRANTY DISCLAIMERS AND OTHER PROVISIONS THAT LIMIT THE LIABILITY OF ZINIO. PLEASE READ THESE TERMS IN THEIR ENTIRETY.   <ol> <li>Description of Service</li> </ol> The Service is operated by Zinio, and includes the Site through which you order, subscribe to and receive various digital magazines and other publications, content and products (collectively, the "Publications"), Z-Pass, Zinio Unlimited and the Zinio Reader applications. Use of the Zinio Reader software is also subject to the  <a href="../reader/license">Zinio Reader License Agreement</a>.   <ol start="2"> <li>Your Account</li> </ol> Certain portions of the Service are available only to individuals who have registered with and obtained a password from Zinio. You may not provide or use a password, email address, or any other information of anyone else in connection with the Services. You agree to provide true, accurate, current and complete information about yourself when you register with or order Publications from Zinio, and to maintain and promptly update that information to keep it true, accurate, current and complete. You are responsible for maintaining the confidentiality of your account and password and for restricting access to your computer, and you agree to accept responsibility for all activities that occur under your account, including the selection, licensing and use of all content and services.   The Service is only available to persons over the age of 18. By registering with Zinio, you certify that you are at least 18 years of age. The Service may contain material which is deemed unsuitable for minors and which may be perceived by others as obscene or disturbing. The Service is not intended to be used by children without the involvement, supervision and consent of parents or guardians. Parents or guardians who allow children to use the Service shall bear sole responsibility for determining whether the content of the Service is suitable for such child.   <ol start="3"> <li>User Conduct</li> </ol> Subject to these Terms, by using the Service, Zinio is granting you a limited, non-exclusive, personal, non-transferable license to retrieve and display the applicable Publication(s) for personal, non-commercial use and for no other purpose. You may not in any way make any Publications available, through any medium: (i) to any person or entity which causes the redistribution of the Publication(s) without the prior written permission of Zinio, (ii) for use in print, television or radio news media (including websites affiliated with or supporting entities engaged in such news distribution) without the prior written permission of Zinio, (iii) to any person or entity which links the Publication(s) to a website, or otherwise distributes or makes available material, which is pornographic, obscene, defamatory, harassing, grossly offensive, malicious in nature, or which infringes, or potentially infringes, any intellectual or other property rights (including copyright, patent, trademark and trade secret rights) of any person, or (iv) to any person or entity which uses or permits the use of the Publication(s) in any way that compromises the integrity thereof or which infringes any copyrights or proprietary interests of any third-party content provider. In addition, you may only use the Service for lawful purposes and in accordance with these Terms, any operating rules established by Zinio from time to time and the  <a href="../reader/license">Zinio Reader License Agreement</a>. Zinio reserves the right to refuse service, terminate accounts, or cancel orders at any time in its sole discretion, including, without limitation, based on any activity by a subscriber in violation of these Terms or applicable laws and regulations.   <ol start="4"> <li>International Users</li> </ol> The Service is controlled, operated and administered by Zinio from its offices and servers located within the United States of America. If you access the Service from a location outside the United States, you are responsible for compliance with all applicable local laws and regulations. You agree that you will not use the Service or any Publications accessed through the Service in any country or in any manner prohibited by the United States Export Administration Act or any other applicable laws or regulations.   <ol start="5"> <li>Intellectual Property</li> </ol> All content included as part of the Service, such as text, graphics, logos, button icons, images, as well as compilations thereof, and all software used on the Site, is the property of Zinio or its suppliers or licensors, and is protected by United States law, and applicable international laws and treaties, including without limitation copyright and other laws and treaties that protect intellectual property and proprietary rights. You agree to observe and abide by all such applicable laws and treaties, and to not alter, obscure or remove any copyright and other proprietary notices, legends (whether outlining restrictions on use or otherwise) contained in any such content. Each third-party content provider owns the copyright in and to all content original to it, including without limitation the Publications delivered or otherwise made available to you through the Service. Except as permitted by the Publication's lawful owner, you acknowledge that you do not acquire any ownership rights in a Publication by downloading a Publication accessed through the Service. Except as explicitly required under applicable copyright laws and treaties or permitted by the features of the Service and Zinio Reader software, you may not modify, reverse engineer, publish, transmit, display, participate in the transfer or sale, create derivative works of, or in any way commercially exploit or provide to a third party access to the content of the Site, the Publications, or any portion of them without the express permission of Zinio and the owner of such content. We do not grant you any licenses, express or implied, to the intellectual property of Zinio or our licensors except as expressly authorized by these Terms or the  <a href="../reader/license">Zinio Reader License Agreement</a>.   <ol start="6"> <li>Third-Party Content</li> </ol> Zinio is a distributor (not a publisher) of the Publications. Accordingly, we have no editorial control over the Publications. Any opinions, advice, statements, services, offers or other information or content expressed or made available by third parties, including those made in Publications offered by the Service, are those of the respective author(s) or publisher(s) and not of Zinio. Zinio does not guarantee the accuracy, completeness, truthfulness, or usefulness of all or any portion of any Publication or any services or offers made by third parties, nor will we be liable for any loss or damage caused by your reliance on information contained in any Publication, or your use of services offered, or your acceptance of any offers made through the Service or the Publications. The Service may contain links to other Internet sites and third-party resources. Zinio does not assume any responsibility or liability for communications or materials available through such linked sites. These links are provided for your convenience only. You are solely responsible for understanding any terms and conditions that may apply when you visit or place an order for products or services through, or otherwise use a third-party site.   <ol start="7"> <li>Modifications to Service</li> </ol> We reserve the right to modify or discontinue, temporarily or permanently, the Service (or any part thereof) if there are reasonable circumstances justifying it, including the removal of Publications, with or without notice. Your continued use of the Service shall serve as your consent to any such modifications to the Service. To the maximum extent permitted by applicable law, you agree that Zinio shall not be liable to you or to any third party for any modification, suspension or discontinuance of the Service.   <ol start="8"> <li>Disclaimer of Warranties</li> </ol> TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE SERVICE AND ALL PUBLICATIONS ARE PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. ZINIO, ITS AFFILIATES, SUPPLIERS, LICENSORS AND AGENTS EXPRESSLY DISCLAIM ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. WITHOUT LIMITING THE FOREGOING, NEITHER ZINIO NOR ITS AFFILIATES, SUPPLIERS, PUBLISHERS, LICENSORS OR AGENTS, MAKES ANY WARRANTY THAT (A) THE SERVICE WILL MEET YOUR REQUIREMENTS, (B) THE SERVICE WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE, (C) THE INFORMATION THAT MAY BE OBTAINED FROM THE USE OF THE SERVICE OR THAT MAY BE CONTAINED IN THE PUBLICATIONS WILL BE ACCURATE OR RELIABLE, OR (D) THE QUALITY OF ANY PUBLICATIONS OR THE SERVICE WILL MEET YOUR EXPECTATIONS.  YOU ARE SOLELY RESPONSIBLE FOR OBTAINING AND MAINTAINING RELIABLE INTERNET CONNECTIVITY. ZINIO IS NOT RESPONSIBLE FOR YOUR INABILITY TO DOWNLOAD OR OTHERWISE ACCESS CONTENT.   ANY MATERIAL DOWNLOADED OR OTHERWISE OBTAINED THROUGH THE USE OF THE SERVICE IS DONE AT YOUR OWN DISCRETION AND RISK AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OR USE OF ANY SUCH MATERIAL.  NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM ZINIO OR THROUGH OR FROM THE SERVICE SHALL CREATE ANY WARRANTY.   <ol start="9"> <li>Limitation of Liability</li> </ol> TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, NEITHER ZINIO NOR ITS AFFILIATES, SUPPLIERS LICENSORS, OR AGENTS BE LIABLE UNDER ANY THEORY OF LAW, FOR ANY INDIRECT, INCIDENTAL, PUNITIVE, OR CONSEQUENTIAL DAMAGES. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE AGGREGATE LIABILITY OF ZINIO FOR CLAIMS ARISING FROM YOUR USE OF THE SERVICE OR PUBLICATIONS OR OTHERWISE SHALL BE LIMITED TO THE FEES PAID BY YOU TO ZINIO FOR THE PORTION OF THE SERVICE OR PUBLICATION GIVING RISE TO THE CLAIM.   <ol start="10"> <li>Indemnification</li> </ol> To the maximum extent permitted by applicable law, you agree to defend, indemnify and hold harmless Zinio, its licensors, suppliers and any third-party content providers and their respective directors, officers, employees and agents from and against all claims, losses, expenses, damages and costs, including attorney's fees, arising out of or resulting from (a) your use of the Service or the Publications, (b) your violation of these Terms, or (c) any activity related to your account (including negligent or wrongful conduct) by you or any other person accessing the Service or the Publications using your account.   <ol start="11"> <li>Monitoring</li> </ol> Zinio may monitor the Service to determine compliance with these Terms and any operating rules established by Zinio, to ensure accurate and proper delivery and functionality of the Services, and to satisfy any law, regulation or authorized government request. Without limiting the foregoing, Zinio may retain the right to remove any content that we, in our sole discretion, find to be in violation of the provisions hereof or otherwise objectionable or in breach of Zinio's or its licensors' obligations.   <ol start="12"> <li>Termination</li> </ol> Zinio may terminate the Service at any time. Without limiting the foregoing, Zinio may, in its sole discretion and without liability, terminate your password, or use of the Service for any reason, including, without limitation, if Zinio reasonably believes that you have violated or acted inconsistently with the letter or spirit of these Terms. Any termination of your access to the Service under any provision of these Terms may involve that Zinio may immediately deactivate or delete your account and all related information and/or bar any further access to the Service. Sections 2, 4, 5, 6 and 8 through 17 shall survive any termination of these Terms and/or the Service.   <ol start="13"> <li>Subscriptions</li> </ol> Certain of our Services are offered on a subscription basis ("Subscription"). A valid credit card or other payment method ("Billing Method") accepted by Zinio is required at the time of registration for such Services, and you agree to be billed periodically, based on the length of your Subscription. You agree to keep all Billing Method and other required information current. All Subscriptions will include "Continuous Service" which enables you to receive uninterrupted access to such Service, and delivery of associated Publications until you cancel your Subscription. Before the end of the initial subscription period, Zinio will inform you in writing of the termination date of such period, allowing you to cancel the subscription before any charge is made. You will be billed automatically, at the end of your then-current offer terms applicable to that Service. The end date of your current Subscription period is available in your account settings. You will be billed each month on the calendar day that your Subscription commenced. Where your Subscription began on a day not contained in a given month, you will be billed on the last day of such month. If your Billing Method has expired at the time of Subscription renewal, Zinio may immediately suspend, deactivate or delete your account and access to the Service. You may cancel a Subscription at any time. Where a Subscription is for a particular Publication, you will receive a refund for any unserved issues (see Refund Policy below). Where the Subscription is for access to Zinio Unlimited or Z-Pass, such access will continue until the end of the then-current subscription period and no refund will be offered.   <ol start="14"> <li>Zinio Unlimited</li> </ol> Zinio Unlimited allows you to access a selection of Publications only while you have an active Subscription. Upon cancellation of your Subscription, you will no longer have any rights to access any Publications downloaded or otherwise accessed while your Subscription was active. You shall not login to Zinio Unlimited on more than five (5) devices for the purposes of accessing Publications. Your use of the Zinio Unlimited applications is subject to the Zinio Reader License Agreement.   <ol start="15"> <li>Free Trials</li> </ol> If you purchase a Subscription to a Service that includes a free trial, you will receive free access to the Publication during the free trial period. If you cancel the Subscription during the free trial period, you will not be billed. If you do not cancel the Subscription during the free trial period, you will be billed at the end of the free trial period for the first Subscription period occurring thereafter applicable to the Service that you purchased. Free trials are limited to one per user, per Service. Before the end of the initial subscription period, Zinio will inform you in writing of the termination date of such period, allowing you to cancel the subscription before any charge is made.   <ol start="16"> <li>Pricing and Tax</li> </ol> All pricing featured on the Site is exclusive of VAT, GST, sales and indirect tax. Purchase transactions will include VAT, GST, sales or indirect tax based on your billing address and the tax rates in effect at the time your transaction is completed. Zinio will only charge tax in countries or states where digital goods are taxable. No customers are eligible for tax exemptions for transactions made on the Service. All pricing and tax on the Zinio iPad and iPhone apps will follow Apple's iTunes Terms and Conditions.   <ol start="17"> <li>Facebook Connect and Passive Sharing</li> </ol> You can register on Zinio using your Facebook account. For security reasons, Zinio will not access your Facebook password. Zinio will only access the Facebook information that you permit to be shared with us in order to facilitate Zinio account creation and to provide you with more targeted communications and promotions. Also, Zinio is compliant with Facebook guidelines and will not publish any reading or sharing action on your Facebook timeline without your permission. You can remove any read action to Facebook from the Zinio website, at any time. If you allow Zinio to publish on your timeline, there will be a delay of 10 seconds before any action is published, and you will be notified when it occurs.   <a name="refund"></a> <ol start="18"> <li>Right of withdrawal and Refund policy</li> </ol> You have the legal right to cancel your subscription for any reason within fourteen (14) days following your subscription, provided that no Publication has been read. However, Zinio has a more generous policy as outlined below. In order to exercise this right, please contact Zinio through email at <a href="mailto:support@zinio.com">support@zinio.com</a>.   <ul> <li> Refund policy for credit card purchases: Zinio will provide a refund for all unserved issues of Publications to the original credit card used for purchase. Single copy purchases will only be refunded in the event that you are unable to download the issue. Please go to Zinio’s help page to request a refund. </li> </ul>   <ul> <li> Refund policy for PayPal purchases: Zinio will provide a refund for all unserved issues to your PayPal account within sixty (60) days of purchase. Due to PayPal policies, all PayPal sales are final after sixty (60) days. </li> </ul>   <ul> <li> Refund policy for iTunes and Googleplay purchases: <a href="https://www.zinio.com/legal/%E2%80%9Chttps:/support.zinio.com/hc/en-us/articles/203947883%E2%80%9C">iTunes</a>and <a href="https://www.zinio.com/legal/%E2%80%9Chttps:/support.zinioapps.com/hc/en-us/articles/209296647%E2%80%9D">Googleplay</a> purchases are subject to their respective third party terms and conditions and cannot be refunded by Zinio. </li> </ul>   <ol start="19"> <li>Miscellaneous</li> </ol> These Terms, the  <a href="../reader/license">Zinio Reader License Agreement</a> and the other rules, guidelines, licenses and disclaimers posted on the Site constitute the entire agreement between Zinio and you with respect to your use of the Site and Service and supersede all previous written or oral agreements between us with respect to the subject matter hereof. These Terms shall be governed by the statutes and laws of the State of Delaware, without regard to the conflicts of laws principles thereof, except where you are a EU-resident consumer and therefore local imperative law may apply. Except where you are a EU-resident consumer and local law apply recognizing your right to submit the conflicts before the courts of the country where you reside or to alternative conflict resolution systems, Any controversy or claim arising out of or relating to your use of the Site or Services shall be settled by arbitration administered by the American Arbitration Association under its Commercial Arbitration Rules. The number of arbitrators shall be one. The place of arbitration shall be Minneapolis, Minnesota. Judgment on the award rendered by the arbitrator may be entered in any court having jurisdiction thereof. No waiver by either party of any breach or default hereunder shall be deemed to be a waiver of any preceding or subsequent breach or default. If any provision of these Terms shall be held to be invalid, illegal or unenforceable, the validity, legality and enforceability of the remaining provisions shall not in any way be affected or impaired. Zinio may assign any contractual relationship arising from these Terms and your use of the Site and/or Services, without prior notice or your consent, to its parent company or other affiliated company, to a successor by operation of law, or by reason of the sale or transfer of all or substantially all of its stock or assets to another entity.   <ol start="20"> <li>Translations</li> </ol> These Terms have been prepared in the English language and, for convenience purposes, may be translated into other languages. In the event of any inconsistencies between one or more translations of these Terms and the original English version, the English version of these Terms shall control.   <ol start="21"> <li>Notification of Changes</li> </ol> From time to time, Zinio may revise these Terms and our Privacy Policy to keep them up to date with Zinio's products and services. Please refer to the Site periodically for any changes. The Effective Date first written above is used to alert you to recent modifications. Your access or use of the Site or the Service subsequent to such an update will signify your consent to be bound by such changes.   <ol start="22"> <li>Our Address</li> </ol> Zinio LLC 7900 International Drive, Suite 800 Bloomington, MN 55425 www.zinio.com    <a name="policy"></a> Privacy Policy  Effective Date: October 31, 2019 Zinio, a wholly owned subsidiary of Naviga Inc. (<a href="https://www.navigaglobal.com">www.navigaglobal.com</a>), knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Privacy Policy (this "Policy") explains Zinio's treatment of information that we collect when you are on our website located at  <a href="https://www.zinio.com">https://www.zinio.com</a> (the "Site") and when you use our products and services (collectively, the "Services"). By using our Site and the Services, you are accepting the practices described in our Policy. This Policy does not apply to the practices of any person or entity other than Zinio, including operators of websites you may visit before or after visiting the Site and the owners or publishers of the Publications you purchase, download or otherwise access through the Service. Each of these may have their own policies to which you may subject. Zinio LLC, a company with registered office in the United States and domiciled at 7900 International Drive, Suite 800, Bloomington, MN 55425, informs you that the personal data that the User provides or that he may provide in the future shall be processed in accordance with this Policy. <ol> <li> What Types of Information Does Zinio Collect About its Users? </li> </ol> Personal Information “Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including: name, title, company name, job function, expertise, postal address, telephone number, or email address. If you submit any Personal Information relating to other people to us or to our service providers through the Site and/or Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy. Other Information “Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. This might include, for instance, browser and device information; App usage data; information collected through cookies, pixel tags, and other technologies; demographic information and other information provided by you; or aggregated information. We use this information to facilitate our operation and for other purposes described below. IP Address Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever you access the Site and/or Services, along with the time of the visit and the page(s) that you visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. Zinio uses IP Addresses to calculate usage levels of the Site and Services, help diagnose problems with its servers, administer the Site, and monitoring the regions from which you navigate to the Site. <ol start="2"> <li>How Does Zinio Collect Information?</li> </ol> We and our service providers may collect Personal Information and Other Information in a variety of ways, including: Information You Give Us: We receive and store information you enter on the Site or give us in any other way. This information includes but is not limited to: <ul> <li> Registration data: When you register for the Services, we ask that you provide basic contact information such as your name, address, and email address. When you register with your Facebook account, we also ask permission to collect your demographic and location information in order to provide you with more targeted communications and promotions. </li> <li> Order data: When you order Publications through the Services, we collect your purchase and address or billing information, including your credit or debit card number and expiration date. </li> <li> Voluntary information: We may collect additional information at other times, including but not limited to, when you provide feedback, change your content or email preferences, respond to a survey, or communicate with Zinio customer support. </li> </ul> Information Collected Automatically: We receive and store certain types of information whenever you interact with us via the Site or the Services (including, without limitation, the Zinio Reader software). To do this, we use cookies and other techniques to gather this information. This information includes but is not limited to: <ul> <li> Computer and device configuration, identification and location: We automatically receive and log information from your browser, including but not limited to your IP Address, the name and ID of your computer, mobile device and other devices, your operating system, browser type and version, CPU speed, connection speed, and location information based on your IP address and as derived from GPS or similar features on your mobile device and other devices. </li> <li> Referral, clickstream, and site interaction data: We may also record the URL you linked from to get to the Site, your clickstream through and from the Site, and other tracking information including the Publications purchased and/or read, the time invested on each Publication, the articles read and, in general, the user’s behaviour related to each Publication. Additionally, the Services (including the Zinio Reader) may store information about the offline reading and behaviour within the Services that we collect once the user goes online. </li> <li> Cookies and Other Similar Technologies: Cookies and other similar technologies may be used to collect Other Information. We may use third parties to serve advertisements on other websites that may be of interest to you, based on information collected about your use of our Site and other websites.  To do so, these companies may place or recognize a unique cookie on your browser (including using pixel tags and web beacons).  Zinio does not recognize automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions. </li> <li> Email delivery and open rates: To help us make our emails more useful and interesting, and to ensure that we are delivering the Publications you have ordered, we often receive a confirmation when you receive and/or open email from Zinio. and when you have read the contents of that email. </li> <li> Software installation, file downloads, and publication access: When you install the Services (including the Zinio Reader software) or download Publications or other files from the Site, we may record when each file transfer begins and ends and any errors that interrupt the transfer. The Services also record whether or not you downloaded and accessed a given Publication and how long you viewed that Publication. </li> </ul> Information We Get from Other Sources: We may receive information about you from other sources, add it to your account information and treat it in accordance with this Policy. This information includes but is not limited to: <ul> <li> Customer and order data from our partners: If you place an order for a Publication directly with the publisher or another Zinio partner for which we provide fulfilment or another service, your account information and order information is passed to us. </li> <li> Updated delivery and address information: We may obtain updated contact information from third parties in order to correct our records and fulfil your orders or deliver communications to you. </li> <li> Demographic and purchase information: We may reference other sources of demographic and purchase information in order to provide you with more targeted communications and promotions. </li> </ul> Zinio also uses web analytics services, which currently include Google Analytics and Crazy Egg Analysis Service. Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google Analytics uses cookies and similar technologies to analyze how users use the Domains. The information generated about Domain usage (including your shortened IP address) is transmitted to Google in the U.S. This information is used to evaluate visitors’ use of the Domain, compile statistical reports on Domain activity, and provide other services related to the Site and Internet use. Google may also collect information about Domain visitors’ use of other websites. For more information about Google Analytics, or to opt out of Google Analytics, please go to: <a href="https://tools.google.com/dlpage/gaoptout">https://tools.google.com/dlpage/gaoptout</a>. Crazy Egg’s Analysis Service is a web analytics service that gives us data about where users are clicking on our site. You can visit their privacy policy at: <a href="https://www.crazyegg.com/privacy">https://www.crazyegg.com/privacy</a> and their opt-out feature at: <a href="https://www.crazyegg.com/opt-out">https://www.crazyegg.com/opt-out</a>. Zinio may also collect aggregated information about users of the Site and Services.  Aggregated Personal Information does not personally identify you or any other user of the Site (for example, we may aggregate Personal Information to calculate the percentage of our users who have a telephone area code). <ol start="3"> <li>How Does Zinio Use Personal Information?</li> </ol> Zinio may use Personal Information and Other Information: <ul> <li> To deliver the Publications and other products you order or that are sent to you; </li> <li> To despond to your inquiries and fulfil your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our Services; </li> <li>To verify access to secure content and your account information;</li> <li> To determine whether you meet the minimum system requirements for use of the Services; </li> <li> To provide you tailored content and instructions, renewal options and promotions; </li> <li> To provide you with customized and personalized recommendations for reading content we think will be of interest to you, when specifically accepted; </li> <li> To provide you with promotional information about our products and services, when specifically accepted. </li> <li> To analyze and understand our audience, improve our Services (including our user interface experiences) and optimize content selection, recommendation algorithms and delivery; </li> <li> To communicate with you and provide you with related customer service and support; </li> <li>To ask you to participate in surveys about our products and services;</li> <li> To send administrative information to you, for example, information regarding the Site and changes to our terms, conditions, and policies; </li> <li>To offer you Services upgrades;</li> <li> For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Site and Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities; and </li> <li> As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations (f) to protect our rights, privacy, safety or property and (g) to allow us to pursue available remedies or limit the damages that we may sustain. </li> </ul> The legal basis for the processing of the user’s personal data is the performance of the contractual relationship between Zinio and the user when using the Site or the Services, as well as the user’s consent provided upon registration into the Services. <ol start="4"> <li> How Will Zinio Share Personal Information It Receives? </li> </ol> Zinio may disclose Personal Information to certain types of third parties for the purposes detailed below: <ul> <li> Subsidiaries and Affiliates: Zinio may disclose Personal Information to its parent and subsidiary entities, and affiliates (collectively, “Affiliates”) for the purposes described in this Policy. </li> <li> Publishers and Business Partners: Zinio may provide Publishers, and other merchants for whom Zinio sells or distributes Publications or other products, with any Personal Information that is necessary to fulfil your requests for their products, programs or services, or to satisfy other core business functions. In such circumstances, these companies will not use your Personal Information for any other purposes without your consent. In some instances, however, when you subscribe to certain publications, Zinio is contractually obligated to provide your Personal Information to these Publishers. The use of your Personal Information by these Publishers is subject to their privacy policies and these Publishers may send you unsolicited messages as well as provide your information to their partners or to other parties, any of whom may use or share your information in accordance with their policies and procedures. Zinio has no control over their use of your Personal Information. In addition, Zinio may disclose Personal Information to its business partners for the purposes described above. Some of Zinio’s third-party business partners may co-sponsor events and other offerings with Zinio. Zinio may share Personal Information with these co-sponsors when you sign up for events or offerings to allow its partners to send you marketing communications and information that may be of interest to you, as permitted under applicable law. </li> </ul> <ul> <li> Agents and Service Providers: Zinio may employ other companies and individuals to perform functions on its behalf such as fulfilling orders, sending email, processing credit card payments, and providing customer service. These companies or individuals will be provided access to Personal Information needed to perform their functions, but these companies and individuals have agreed or will agree to not use your Personal Information for other purposes. </li> <li> Payment Card Information: By submitting your credit or debit card information through the Services, you expressly consent to the sharing of your information with third-party merchants, subscription and billing processors, and payment processors. These third parties may store your credit or debit card information so you can use the Services in the future. Zinio transmits your credit or debit card information to these third parties but does not store such information. Zinio cannot guarantee that transmissions of your credit or debit card information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third-party service providers. Zinio assumes no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. </li> <li> Site and Social Media Pages: Personal Information may also be disclosed by you through the Site, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials. This information may appear in public ways, such as through search engines or other publicly available platforms, and may be “crawled” or searched by third parties. Please do not post any information that you do not want to reveal to the public at large. </li> <li> Protection of Zinio and others: Zinio releases account and other Personal Information when release is appropriate to comply with the law; to enforce or apply its Terms of Service, the  <a href="../reader/license">Zinio Reader License Agreement</a>, or other agreements; or to protect the rights, property, or safety of the Site, its users, or others.  Zinio is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, i.e., Zinio may release Personal Information when it believes that release is necessary or appropriate (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce or apply our conditions of use and other agreements; (e) to protect its operations or those of any of its Affiliates; (f) to allow Zinio to pursue available remedies or limit the damages that it may sustain; and (g) to protect the rights, privacy, property, or safety of Zinio, its employees, Affiliates, users, or any other person or entity. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. </li> <li> Business transfers: Zinio may transfer Personal Information it collects in connection with a merger, acquisition or sale of all or most of the assets of Zinio related to the Site and/or the Services. You acknowledge that such transfers may occur, and that any acquirer of Zinio may continue to use your Personal Information as set forth in this Policy. </li> <li> With your consent: Other than the cases above, you will be notified before your Personal Information will be communicated to a third party, and will be able to decide not to share it.  </li> </ul> Zinio reserves the right to use and disclose Other Information, including anonymous and aggregate information derived from your Personal Information, to inform publishers, partners, and other interested parties as to the usage habits or characteristics of Zinio's user base; and to serve any other business purposes. If Zinio is required to treat Other Information as Personal Information under applicable law, then Zinio may use it for all the purposes for which it uses and disclose Personal Information. In some instances, Zinio may combine Other Information with Personal Information (such as combining your name with your geographical location). In such case, Zinio will treat the combined information as Personal Information for as long as it is combined. <ol start="5"> <li> When will Zinio Send Email Communications To Users? </li> </ol> Zinio does not send unsolicited email, but we do send email communications to our users in connection with the provision of the Services. The following outlines the types of email Zinio sends to our users and the choices you have about which messages to receive: <ul> <li> Messages required to service orders you place for Publications and products fulfilled by Zinio: Zinio will send you email notifying you of the availability of each Publication or other product or service that you order either directly from Zinio or from one of our publisher or other merchant partners. </li> <li> Messages required to service your Zinio account: Zinio may send you the following messages: (a) for newly registered users, a welcoming email;(b) messages confirming each order you place directly on the Site; (c) messages confirming your account changes; (d) messages inviting you to participate in customer surveys; and (e) messages informing you of important product or service updates related to our business. </li> <li> Marketing messages about Publications you receive: If you have previously consented, we may send you marketing messages related to the Publications you receive including, for example, messages encouraging you to purchase additional single copies or to subscribe to Publications. </li> <li> Optional marketing messages from Zinio: Registered users may also occasionally receive information or special promotions from Zinio about additional Publications, products or services if they have elected to do so. You may update your preference with regard to receiving such messages in the "email preferences" in the "account settings" area of the Site. </li> <li> Optional marketing messages from trusted third parties: With your consent, Zinio may share your Personal Information (not including your credit card information) with trusted third parties so that you may receive information or opportunities from these third parties about relevant products and services they offer. You may update your preference in the "email preferences" in the "account settings" area of the Site. The use of your Personal Information by these third parties will be subject to their respective privacy policies. </li> </ul> <ol start="6"> <li>How Does Zinio Secure Personal Information About Me?</li> </ol> Zinio has implemented organizational, technical, and administrative measures to protect Personal Information within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Information from loss, misuse, interference and unauthorized access, modification and disclosure, you should be aware no security procedures or protocols are ever guaranteed to be one hundred percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Information online. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with Section 15 below. <ol start="7"> <li> How Can I Access, Correct, Amend or Remove Information About Me? </li> </ol> Individuals have the right to access their personal data. If you would like to access, correct, amend, remove or limit the use or disclosure of any Personal Information about you that has been collected and stored by Zinio, or close your account, please notify us at <a href="mailto:support@zinio.com">support@zinio.com</a> so that we may evaluate and respond to your request in accordance with applicable law.  Please be aware that any unfulfilled subscriptions may be cancelled without refund and you will have to re-register in order to use the Service. It is your responsibility to request a refund from Zinio or the appropriate merchant. below. Alternatively, to review or update your Personal Information, or to alter your email preferences, or preferences regarding how we share your Personal Information, go to "email preferences" in the "account settings" area of the Site. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will use commercially reasonable efforts to respond to your request within thirty days. Please note that we may need to retain certain information for recordkeeping purposes, to comply with applicable law (including laws outside your country of residence), and/or to complete any transactions that you began prior to requesting such access, change, or deletion. We hereby inform you that Zinio holds an establishment within the European Union, as set forth in Section 15. <ol start="8"> <li> For How Long Will Zinio Retain My Personal Information? </li> </ol> Zinio will retain your Personal Information for the period necessary to fulfill the legal obligations of Zinio regarding the Service and the purposes outlined in this Policy, unless a longer retention period is required or permitted by law.  Usage data collected automatically by Zinio may be anonymized and stored indefinitely. <ol start="9"> <li>What Choices Do I Have?</li> </ol> You can always opt for Zinio to not to disclose information to you. However, if you elect to opt out, you may be limiting some Services we can provide to you. You will not receive product updates and other marketing related emails. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative or account related messages. You may opt-out of receiving marketing messages from Zinio or our Affiliates by sending an email to <a href="mailto:support@zinio.com">support@zinio.com</a>. We will try to comply with your request(s) as soon as reasonably practicable. In addition, pursuant to the obligations and requirements imposed upon Zinio under applicable data protection legislation, you may have the right to restrict and/or revoke authorisation for Zinio to process and disclose your Personal Information, and may also exercise the rights of access, rectification, deletion and objection, the right to data portability and the right to complain to a supervisory authority. You may exercise these rights by contacting <a href="mailto:dataprotection@zinio.com">dataprotection@zinio.com</a>, or by mail to Zinio’s establishment in the European Union (as set forth in Section 15) .  Please note that we may need to retain certain Personal Information for recordkeeping purposes, to comply with applicable law (including laws outside your country of residence), and/or to complete any transactions that you began prior to such request. <ol start="10"> <li>Can Children Use Zinio’s Site and Services?</li> </ol> The Zinio Site and Services are not intended for minors under the age of 18. Zinio does not knowingly or specifically collect information about minors under the age of 18 and believes that children of any age should get their parents’ or legal guardians’ consent before providing any Personal Information. If you believe that we have mistakenly or unintentionally collected such information, please notify us at <a href="mailto:dataprotection@zinio.com">dataprotection@zinio.com</a> so that we may delete the information from our servers. <ol start="11"> <li>Third Party Sites</li> </ol> We may permit you to link to other websites on the Internet through direct links or through applications such as “share” or “Like” buttons, and other websites likewise may contain links to the Sites. The information practices or content of such other websites is governed by the privacy statements of those websites and not by this Policy. We encourage you to review the privacy policies found on such other websites, services, and applications to understand how your information may be collected and used. We are not responsible for the collection, use and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or the Social Media Pages. <ol start="12"> <li>Sensitive Information</li> </ol> Please do not send Zinio or disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Zinio web site or via other means. <ol start="13"> <li>Changes to this Policy</li> </ol> Zinio may amend this Policy from time to time. The “Effective Date” legend at the top of this page indicates when this Policy was last revised. If we make any material changes to this Policy, we will provide a notice on the Site and Services.  In addition, we may notify you by email (sent to the email address specified in your account) prior to the change becoming effective.  We encourage you to periodically review this page for the latest information on our privacy practices. Any changes to this Policy will become effective when we post the revised Policy on our web site, unless a later “Effective Date” is set forth at the top of the revised Policy. Your continued use of the Site and Services after the revised Policy takes effect shall be construed as your agreement to the revised Policy. <ol start="14"> <li>Translations</li> </ol> This Policy has been prepared in the English language and, for convenience purposes, may be translated into other languages.  In the event of any inconsistencies between one or more translations of this Policy and the original English version, the English version of this Policy shall control. <ol start="15"> <li>International Transfer of Data</li> </ol> Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using this site or disclosing information to us you consent to the transfer of information to countries outside of your country of residence, including (but not limited to) the United States, Australia, Denmark, India, Spain, Sweden, and the UK, which could have different data protection rules than those of your country or the country in which you were located when you initially provided the information. Where required, we put in place a solution to ensure that Personal Data transferred outside of the EEA is subject to adequate protection. Zinio has responsibility for the processing of personal information it receives under the Privacy Shield Principles and subsequent transfers to a third party acting as an agent on its behalf. Zinio further commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities about human resources data transferred from the EU and Switzerland in the context of the employment relationship.  EU-U.S. and Swiss-US Privacy Shield When transferring any Personal Data from the EEA and Switzerland to the U.S., Zinio adheres to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce. Zinio adheres to the Privacy Shield Principles. Zinio complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom and/or Switzerland to the United States.  Zinio’s parent company (Naviga Inc. (“Naviga”)), has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Naviga’s certification, please visit <a href="https://www.privacyshield.gov/">https://www.privacyshield.gov/</a>.  For the purposes of enforcing compliance with the Privacy Shield, we are subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.  If Zinio has received your Personal Data in the U.S. and subsequently transfers it to a third-party agent or service provider for processing, and such third-party agent or service provider processes your Personal Data in a manner inconsistent with the Privacy Shield Principles, Zinio remains responsible under the Privacy Shield Principles, unless Zinio can prove that it is not responsible for the event giving rise to the damage. <ol start="16"> <li>Questions, Concerns or Complaints</li> </ol> Your privacy is important to us. If you have any questions, concerns, or complaints regarding the way we collect and handle your information, please contact us by email at <a href="mailto:dataprotection@zinio.com">dataprotection@zinio.com</a>. Since email communications are not always secure, please do not include sensitive information in your emails to us.  You may also contact us by mail as follows:   Within the United States:   Zinio 7900 International Drive, Suite 800 Bloomington, MN 55425     Within the European Union:   Zinio Avenida Diagonal 605, 8ª planta 08028 Barcelona, Spain   Zinio will take any privacy complaint seriously and any complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need. In compliance with the Privacy Shield Principles, Zinio commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Zinio at: <a href="mailto:dataprotection@zinio.com">dataprotection@zinio.com</a>.  Zinio, through Naviga, has further committed to refer unresolved Privacy Shield complaints to Privacy Trust (see <a href="https://www.privacytrust.com/cert/296507.html">https://www.privacytrust.com/cert/296507.html</a>), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit <a href="https://www.privacytrust.com/drs/Naviga">https://www.privacytrust.com/drs/Naviga</a> for more information or to file a complaint.  The services of Privacy Trust are provided at no cost to you. Naviga provides the possibility, under certain conditions, for the individual to invoke binding arbitration. For the purposes of enforcing compliance with Privacy Shield, we are subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.        <a name="cookies"></a> Cookies Policy.    Last updated: October 15, 2019   This page tells you about the use of Cookies and similar technologies by Zinio LLC, a Delaware limited liability company (on behalf of itself and its subsidiaries, "us," "we," or “us”), on our websites and other online or mobile applications (each a "Site" or collectively "Sites"). Should you have any queries about this policy, please contact us at <a href="mailto:support@zinio.com">support@zinio.com</a>.   We use these technologies to administer the Sites, analyze trends, to track users' movements around the Sites and to provide personalized users’ experiences and targeted recommendations and advertisements (as applicable). This page explains what these technologies are and sets out your rights to control our use of them.   When you first access the Sites, you may receive a message advising you that cookies and similar technologies are in use. By clicking "accept", closing the message, or continuing to browse the Sites, you signify that you understand and agree to the use of these technologies, as described in this Cookies Policy.   You do not have to accept cookies and consent can be withdrawn at any time (see How to Control Cookies, below). You can change your browser settings to refuse or restrict cookies, and you may delete them after they have been placed on your device at any time. If you do not accept or delete our cookies, some areas of our Sites that you access may take more time to work or may not function properly.   <ol> <li>What Are Cookies</li> </ol>   Cookies are small files containing a string of characters which we store on your computer or mobile device when you visit the Sites. When you visit the Sites again, the cookies allow us to recognize your browser. Cookies may store your preferences and other information but cannot read data off your hard disk or read cookie files created by other sites.   Cookies set by a website owner are called "first party cookies." Cookies set by parties other than the website owner are called "third party cookies". Third party cookies enable third party features or functionality to be provided on or through the Sites (i.e. advertising, social media functions and analytics).   <ol start="2"> <li>The Cookies We Use</li> </ol>   When you use and access the Service, we may place a number of cookies files on your computer or mobile device.   We use cookies for a variety of reasons. Cookies make it easier for you to log on to and use the Sites during visits. The aggregate information collected permits us to analyze traffic patterns and target the interests of our users. This helps us provide you with a better experience by improving the content and making our Sites easier to use.   We may use the following categories of cookies in connection with the Sites:   <ul> <li> Strictly Necessary Cookies: These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our websites. </li> </ul>   <ul> <li> Performance and Functionality Cookies: These are used to recognize you when you return to our Site. This enables us to personalize our content for you and remember your preferences but are non-essential to the performance of the Site. By way of example, these cookies may remember your choice of language, currency or region, bookmarked stories and pages, last page read, archived issues, and cart preferences (products in cart). </li> </ul>   <ul> <li> Analytical or Customization Cookies: These cookies collect information about how users access and move through the Site. We use this information in either aggregate form to help us to improve the way our Site works, or to personalize our Site to your interests. </li> </ul>   <ul> <li> Advertising Cookies: These cookies are used to make the advertising displayed on the Site more relevant to you. These cookies prevent ads reappearing and ensure that ads are properly displayed. Certain third-party cookies may track users over different websites are will provide ads relevant to your interests. </li> </ul>   <ul> <li> Social Media Cookies: These cookies allow us to integrate social media functions into our Site and may also be used for advertising purposes. </li> </ul>   Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements.   <ol start="3"> <li>What Are Your Choices Regarding Cookies</li> </ol>   When you first access the Sites, you may receive a message advising you that cookies and similar technologies are in use. By clicking "accept", closing the message, or continuing to browse the Sites, you signify that you understand and agree to the use of these technologies, as described in this Cookies Policy.   You do not have to accept cookies and consent can be withdrawn at any time, although you may not be able to use certain features on the Sites, you may not be able to store your preferences, and some of our pages might not display properly. You can do this by activating the setting on your browser that allows you to refuse the setting of all or some cookies.   Please follow the links below to helpful information for the most popular browsers:   <ul> <li>Microsoft Internet Explorer:</li> </ul> <a href="https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies">https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies</a>   <ul> <li>Google Chrome:</li> </ul> <a href="https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en">https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en</a>   <ul> <li>Mozilla Firefox:</li> </ul> <a href="https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences">https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences</a>   <ul> <li>Apple Safari:</li> </ul> <a href="https://support.apple.com/kb/PH21411?locale=en_US">https://support.apple.com/kb/PH21411?locale=en_US</a>   In addition, you can exercise advertising cookie choices by visiting: <a href="https://www.aboutads.info/choices/">https://www.aboutads.info/choices/</a>, <a href="https://www.networkadvertising.org/choices/">https://www.networkadvertising.org/choices/</a>; or <a href="https://youronlinechoices.com/">https://youronlinechoices.com/</a>.   <ol start="4"> <li>Web Beacons</li> </ol>   As well as cookies, we may use other technologies to recognize and track visitors to our Sites. A web beacon (also known as a "tracking pixel" or "clear GIF") is a clear graphic image (typically a one-pixel tag) that is delivered through a web browser or HTML e-mail, typically in conjunction with a cookie.   Web beacons allows us, for example, to monitor how users move from one page within our Sites to another, to track access to our communications, to understand whether users have come to our Sites from an online advertisement displayed on a third-party website, to measure how ads have been viewed and to improve site performance.   <ol start="5"> <li>Where Can You Find More Information About Cookies</li> </ol>   You can learn more about cookies and the following third-party websites:   <ul> <li> AllAboutCookies: <a href="https://www.allaboutcookies.org/">https://www.allaboutcookies.org/</a> </li> <li> Network Advertising Initiative: <a href="https://www.networkadvertising.org/">https://www.networkadvertising.org/</a> </li> </ul>   <ol start="6"> <li>General</li> </ol>   Further information about how we use your information is available in our Privacy Policy: <a href="https://www.zinio.com/legal/terms#policy">https://www.zinio.com/legal/terms#policy</a>.    We reserve the right, in our sole discretion, to make changes or modifications to this Cookies Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Policy.  It is your responsibility to periodically review this Cookies Policy to stay informed of updates. You will be subject to, and will be deemed to have been made aware of and to have accepted, the changes to this Cookies Policy by your continued use of the Sites after the date such revised Cookies Policy is posted.   This Policy has been prepared in the English language and, for convenience purposes, may be translated into other languages.  In the event of any inconsistencies between one or more translations of this Policy and the original English version, the English version of this Policy shall control.   Should you have other questions or concerns about this Cookies Policy and practices, please contact us at <a href="mailto:support@zinio.com">support@zinio.com</a>.     <a name="california-appendix"></a> PRIVACY NOTICE FOR CALIFORNIA RESIDENTS Effective Date: January 1, 2020 Last Updated: March 18, 2020 Zinio, a wholly owned subsidiary of Naviga Inc. (<a href="https://www.navigaglobal.com/">www.navigaglobal.com</a>), This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in ZINIO (“ZINIO,” “we,” “our” or “us”) Privacy Policy (<a href="https://www.zinio.com/legal/terms#policy">https://www.zinio.com/legal/terms#policy</a>) and applies solely to all visitors, users, and others who reside in the State of California ("consumers" “your” or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. Any terms not otherwise defined herein or in the CCPA shall have the meaning set forth in ZINIO´s Privacy Policy. Please read this statement carefully to understand our policies and practices regarding your information and how we will treat it. When you use the Services, you consent to our collection, use and disclosure of information about you and your clients described below. If you do not agree with our policies and practices, your choice is to not use the Services. This Privacy Notice may change from time to time. Your continued use of the Services after we make changes to this Privacy Notice is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates <ol type="I" start="I"> <li>Information We Collect</li> </ol> This Privacy Notice applies to information we collect: <ul> <li>through the Services and/or our website (<a href="https://www.zinio.com">https://www.zinio.com</a>)</li> <li>in email, text, and other electronic messages between you and ZINIO, whether through the Services or otherwise; and</li> <li>through any software or applications you download or install relating to the Services; and where such collected information identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("Personal Information").</li> </ul> In particular, ZINIO has collected the following categories of Personal Information from its consumers within the last twelve (12) months: <table cellpadding="8" cellspacing="1"> <col> <col> <tr> <td style="border: 1px solid black"> Category </td> <td style="border: 1px solid black"> Examples </td> </tr> <tr> <td height="28" style="border: 1px solid black"> Identifiers. </td> <td style="border: 1px solid black"> A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. </td> </tr> <tr> <td style="border: 1px solid black"> Commercial </td> <td style="border: 1px solid black"> Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. </td> </tr> <tr> <td style="border: 1px solid black"> Usage. </td> <td style="border: 1px solid black"> Information on the user’s interaction with the Services. </td> </tr> <tr> <td style="border: 1px solid black"> Geolocation data. </td> <td style="border: 1px solid black"> Physical location, generally. </td> </tr> </table> Personal information does not include: <ul> <li>Publicly available information from government records;</li> <li>Deidentified or aggregated consumer information.</li> <li>Information excluded from the CCPA's scope, like: <ul> <li>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) or clinical trial data; and</li> <li>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.</li> </ul> </li> </ul> ZINIO obtains the categories of Personal Information listed above from the following categories of sources: <ul> <li>Directly from you. For example, from forms you complete or products and services you purchase.</li> <li>Indirectly from you. For example, from observing your actions using the Services.</li> <li>Records and copies of your correspondence (including email addresses), if you contact us.</li> <li>Your responses to surveys that we may ask you to complete for research purposes.</li> <li>Details of transactions you carry out through the Services and of the fulfillment of your orders.</li> </ul> This Privacy Notice does not apply to information collected by: <ul> <li>Us offline or through any other means, including on any other website operated by ZINIO or any third party (including our affiliates and subsidiaries); or</li> <li>Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or in the Services.</li> </ul> <ul> <ol type="a"> <li>Information We Collect Through Automatic Data Collection Technologies</li> </ol> </ul> As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: <ul> <li>Details of your visits to the Services, including traffic data, location data, logs, and other communication data and the resources that you view or interact with through the Services and/or on the Sites.</li> <li>Information about your computer and internet connection, including your IP address, operating system, and browser type.</li> </ul> The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve the Services and to deliver a better and more personalized product. The technologies we use for automatic data collection may include: <ul> <li>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 the Services. 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 Sites or the Services.</li> </ul> <ol start="2" type="I"> <li>Use of Personal Information</li> </ol> We may use information we collect about you or that you provide to us, including any Personal Information: <ul> <li>To present the Services and its contents to you.</li> <li>To provide you with information, products, or services that you request from us</li> <li>To fulfill any other purpose for which you provide it.</li> <li>To provide you with notices about your account, including expiration and renewal notices</li> <li>To personalize your experience using the Sites and the Services, and to deliver content and product and service offerings relevant to your interests, including personalized recommendations, targeted offers and ads through our Sites, the Services, third-party sites, and via email or text message (with your consent, where required by law). </li> <li>To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.</li> <li>To notify you about changes to the Services or any products or services we offer or provide though it.</li> <li>In any other way we may describe when you provide the information or as otherwise set forth in the CCPA.</li> <li>For any other purpose with your consent.</li> </ul> <ol start="3" type="I"> <li>Sharing Personal Information</li> </ol> ZINIO may disclose your Personal Information to a third party for a business purpose or when they integrate with the Services through an API or other means. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. <ul> <ol type="a"> <li>Disclosures of Personal Information for a Business Purpose</li> </ol> </ul> We may use or disclose the Personal Information we collect for one or more of the following business purposes: <ul> <li>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 products or 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 provide support.</li> <li>To provide, support, personalize, and develop the Sites, the Services, and other products and services.</li> <li>To create, maintain, customize, and secure your account with us.</li> <li>To process your requests, purchases, transactions, and payments and prevent transactional fraud</li> <li>To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.</li> <li>To help maintain the safety, security, and integrity of the Services, our Sites, products and services, databases and other technology assets, and business.</li> <li>For testing, research, analysis, and product development, including to develop and improve the Services, Sites, products, and services.</li> <li>To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.</li> <li>To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ZINIO麓s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by ZINIO about our customers and/or users is among the assets transferred.</li> </ul> ZINIO will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice. <ul> <ol start="2" type="a"> <li>Other disclosures of Personal Information</li> </ol> </ul> In addition to the above, ZINIO may also disclose your Personal Information: <ul> <li>To comply with any court order, law, or legal process, including to respond to any government or regulatory request.</li> <li>To enforce or apply any agreements, including for billing and collection purposes.</li> <li>If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ZINIO, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.</li> </ul> <ul> <ol start="3" type="a"> <li>Sales of Personal Information</li> </ol> </ul> In the preceding twelve (12) months, ZINIO has not sold Personal Information it has received by and through the Services to any third party. However, we have de-identified and aggregated certain information for both internal and commercial use. <ul> <ol start="4" type="a"> <li>Choices about how we use and disclose Personal Information</li> </ol> </ul> 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: <ul> <li>Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Sites and/or the Services may then be inaccessible or not function properly.</li> <li>Promotional Offers. If you do not wish to have your email address/contact information used by ZINIO to promote our own or third parties' products or services, you can opt-out by unsubscribing within the email sent to you or by sending us an email stating your request to <a href="mailto:dataprotection@zinio.com">dataprotection@zinio.com</a>.</li> </ul> This opt out does not apply to information provided to ZINIO as a result of a product or service purchase, product service experience or other transaction. <ol start="4" type="I"> <li>Your Rights and Choices</li> </ol> The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. <ul> <ol type="a"> <li>Access to Specific Information</li> </ol> </ul> You have the right to request that ZINIO disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights), we will disclose to you: <ul> <li>The categories of Personal Information we collected about you.</li> <li>The categories of sources for the Personal Information we collected about you.</li> <li>Our business or commercial purpose for collecting or selling that Personal Information.</li> <li>The categories of third parties with whom we share that Personal Information.</li> <li>The specific pieces of Personal Information we collected about you.</li> </ul> <ul> <ol start="2" type="a"> <li>Deletion Request Rights</li> </ol> </ul> You have the right to request that ZINIO delete any of your Personal Information that we collected from you and retained, subject to certain exceptions including regulatory data retention requirements. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: <ul> <li>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, or otherwise perform our contract with you.</li> <li>Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.</li> <li>Debug products to identify and repair errors that impair existing intended functionality.</li> <li>Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.</li> <li>Comply with a legal obligation.</li> <li>Make other internal and lawful uses of that information that are compatible with the context in which you provided it.</li> </ul> <ul> <ol start="3" type="a"> <li>Exercising Access, and Deletion Rights</li> </ol> </ul> To exercise the access, and deletion rights described above, please submit a verifiable consumer request to us through the Services, by telephone at +1 (855) 979-4646, or by email at <a href="mailto:dataprotection@zinio.com">dataprotection@zinio.com</a>. Only you 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 or as a user of the Services with regards to ZINIO as your Service Provider (meaning at the request of an individual whose Personal Information you have provided to us in the normal course of and purpose for using the Services). You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must: <ul> <li>Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.</li> <li>Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. </li> </ul> 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. We do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. <ul> <ol start="4" type="a"> <li>Response Timing and Format</li> </ol> </ul> We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 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 disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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 <ol start="5" type="I"> <li>Data Security</li> </ol> We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone, or use common passwords across multiple sites Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained within the Services. <ol start="6" type="I"> <li>Children Under the Age of Sixteen</li> </ol> The Services are not intended for children under 16 years of age. No one under age 16 may provide any Personal Information to or in the Services. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information through the Sites, the Services or through any of its features, register on the Sites or Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us as set forth below. <ol start="7" type="I"> <li>Changes to this Privacy Notice</li> </ol> ZINIO reserves the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated notice with the applicable effective date. Your continued use of the Services following the posting of changes constitutes your acceptance of such changes. <ol start="8" type="I"> <li>Contact Information</li> </ol> If you have any questions or comments about this Privacy Notice, the ways in which ZINIO collects and uses your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at: Phone: (855) 979-4646 or (866) 970 0605 (toll free) Website: <a href="https://www.zinio.com">www.zinio.com</a> Email: <a href="mailto:dataprotection@zinio.com">dataprotection@zinio.com</a> Postal Address: <address> ZINIO LLC Attn: Legal Department 7900 International Drive, Suite 800 Bloomington, MN 55425 United States </address> </body></html>