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Privacy Statement OUR PRIVACY COMMITMENTS We've developed our privacy policy from industry guidelines and standards, and local, national, and international laws and requirements. All privacy practices and methods described herein only apply insofar as permitted by the applicable standards, laws and requirements and as limited by the website or interactive banner you are visiting. INFORMATION COLLECTED AND HOW WE USE IT Personal information received from you online will only be used by the brand to which you submitted your information, the Graham Webb Company, a purchaser of the brand, and other Graham Webb brands, except as otherwise required by law or as Graham Webb discloses to you when the information is collected. a) Personal Information If you opt not to provide us with personal information you can still access our websites; however you may be unable to participate in certain promotions or receive product information offered through Graham Webb's websites or interactive advertisements b) Aggregate and Statistical Data Neither our cookies nor web beacons nor web log information collects any personal information. They do not contain personal information such as your name or email address. In some cases we may also collect information about you that you voluntarily submit and which is not personal, such as general statistical information like age, gender, household size, zip/postal code, preferences and interests. INFORMATION WE COLLECT You are in control of the personal information you provide to Graham Webb online. You can: 1. Ask for a copy of your personal information 2. Ask for your personal information to be corrected or updated 3. Ask us to remove your personal information from our records To do this, please contact us using the links provided later in this statement. Graham Webb will use reasonable efforts to fulfill you request. At some Graham Webb sites you can order product samples, enter contests, vote in polls or otherwise express an opinion, subscribe to one of our services such as newsletters, or participate in one of our online forums or communities. These programs require you to submit some information in order to participate. These programs and the types of information required are described in more detail below. Registration/Subscriptions/Product Samples Requests: To fully use our websites, visitors may need to register using our online registration forms, where visitors will be required to provide us with their personal information. Visitors may also be asked to select a user ID and password. Further, to register for certain services or become a member of certain communities, we may ask visitors to submit their name, email address, home address, and zip/postal code. In addition, we ask for country of residence and age so that we can comply with all applicable privacy regulations. You can further make choices about receiving email newsletters and alerts from Graham Webb brands. You can always decide not to receive or stop receiving any email from Graham Webb brands that you do not want. Contests/Sweepstakes: Graham Webb may run contests, sweepstakes and other promotions on its Sites or through interactive banner ads. These events which may ask you to provide personal information which is needed in order to administer the contest, sweepstakes or promotions and to notify winners. Referrals: Occasionally, visitors may have the opportunity to forward product sampling opportunities or other information on the website to friends/relatives or to send messages from our websites or interactive advertisements to friends/relatives. This personal referral information you provide to facilitate this communication is used on a one-time basis or stored only for analysis purposes, and is not further used by Graham Webb to recontact referred individuals, except in circumstances where we obtain consent from the people you have referred to receive communications from us. Questionnaires, Surveys and Profile Data: Graham Webb may occasionally ask visitors to complete surveys and opinion polls about their interests, needs, and attitudes. Surveys help us provide better services and products that meet customer needs. Participation is completely voluntary and these surveys are optional. Consumer Services and Contact Information: If you provide our consumer service representatives with feedback on your experiences with our products/services or otherwise submit questions to our consumer service representatives or webmasters, you will be asked to supply personal information for our record keeping and follow-up. Employment Information: Personal information you may submit in connection with employment inquiries will be used only for recruitment and future internal consideration. It will be accessible solely by persons responsible for recruitment for Graham Webb entities. This information will be kept no longer than 2 years. HOW WE USE YOUR INFORMATION We also use personal information about you to improve our marketing and promotional efforts; to statistically analyze site usage; to improve our content and product offerings; and to customize our sites' content, layout and services. We may also use your information to deliver information to you that, in some cases, is targeted to your interests, such as targeted banners, new services and promotions. We believe these uses allow us to improve our site and better tailor it to meet our visitors' needs. Graham Webb does not collect personal information automatically, but we may combine non personal information collected automatically (e.g., through cookies) with your previously submitted personal information. Graham Webb occasionally sends visitors who have opted-in emails describing new products, promotions or events. These services are optional and you may opt-out of these services completely, at any time. We will only store your personal information for a reasonable period of time. b) Aggregate and Statistical Data DATA SHARING AND TRANSFER Occasionally, we may share personal information from you (such as name, mailing addresses and email addresses) with vendors, contractors or partners of Graham Webb in connection with services that these individuals or entities perform for or with Graham Webb. These vendors, contractors or partners are restricted from using this data in any way other than to provide services for Graham Webb, and they may not share or resell this data. The services they provide for GRAHAM WEBB include mailing product samples, or contacting the winners of GRAHAM WEBB contests. Graham Webb also reserves the right to share the information to respond to duly authorized information requests of governmental authorities or where required by law. b) Data Transfers Graham Webb adheres to U.S./EU Safe Harbor principles. If you feel that Safe Harbor privacy principles may have been violated by Graham Webb, you may contact us with your complaint. COOKIES AND WEB BEACONS a) Cookies b) Web Beacons Third party advertising networks that serve ads onto any Graham Webb web site may use cookies and/or web beacons in their advertisements. Graham Webb retains no control over such third party cookies and/or web beacons and does not have access to the information related to third party cookies and/or web beacons. CHOICE To Prevent Further Use of Your Personal Information - You will be asked for your country of residence, then provided with a way to remove yourself from Graham Webb's online programs. ADVERTISING PARTNERS CHILDREN'S PRIVACY Graham Webb respects all applicable national and international children's privacy regulations. Graham Webb generally does not intend to collect personal information from children. In the event it does, we will collect such information in accordance with local laws and regulations on children's privacy. If we collect personal information from children, we ask only for the information necessary to participate in the program for which the child is registering. Where appropriate, Graham Webb will specifically instruct children not to submit such information on our websites and/or will take reasonable steps to ensure parental consent to such submission. For instance, we may ask for a visitor's age, birthday, or birth year in order to determine whether or not the visitor is a child. If the birthday or birth year entry reveals a child is under the age limit as defined by the applicable local or national law, we will not allow the child to continue without the guardian's consent. If a child has provided us with personal information, a parent or guardian of that child may contact us at the email address or address listed at the bottom of this Privacy Statement if they would like this information deleted from our records. We will use reasonable efforts to delete the child's information from our databases. We do not filter advertisements or other content that children may view through our sites, and they could receive content and materials from the Internet and/or advertising that are inappropriate for children. If you would like to contact us about your or your child's personal information, or to find out how you can have your child's personal information removed from our database, please see the Access To Your Information and Complaints section later in this document. DATA SECURITY AND RESPONSIBILITY ACCESS TO YOUR INFORMATION AND COMPLAINTS a) Access, Correct, Update Your Personal Information b) Complaints GRAHAM WEBB Privacy Team Graham Webb will be happy to respond to your questions and comments. Please feel free to use your native language when contacting us at this address. If you do not receive a response to your inquiry - or if you feel your inquiry has not been satisfactorily addressed - GRAHAM WEBB's participation in 3rd party privacy trustmark programs provides you with another avenue to submit a complaint. LINKS TO OTHER SITES YOUR ACCEPTANCE OF OUR PRIVACY PRACTICES Please check back for updates to this Privacy Statement or our Executive Summary. Last updated: December 1, 2004 |
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