Yearbook, Website and Web Applications Privacy Policy

We at Walsworth Publishing Company, Inc. (“Walsworth”) know that your privacy is important. This privacy policy is designed to assist you in understanding how we will collect and use certain personal data. Specifically, this privacy policy only applies to personal data that is processed in (i) our mobile applications Yearbook Snap and Yearbook Shout (the “Mobile Apps”), the Community Upload information system, and (ii) the Members Only and the Online Design web applications (collectively, the “Services”), and then only in cases where the data subject is using the Services in connection with a Walsworth client located in the European Economic Area (EEA) or Switzerland who is bound by and complies with the Walsworth Insert for Terms and Conditions for European Contracts. Please read this privacy policy to learn more about the ways in which we collect and use your personal data. If we make any material changes to this privacy policy, we will notify you in accordance with the process described in the Changes to This Privacy Policy section of this privacy policy.  By using our Services, you consent to our processing of your personal data as described in this privacy policy.

EU-U.S. and Swiss-U.S. Privacy Shield Frameworks
[Note: our Privacy Shield compliance assessment is currently underway; however, we have not yet completed this process.] With respect to personal data processed in the scope of this privacy policy, Walsworth complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, the “Privacy Shield”) as adopted and set forth by the U.S. Department of Commerce and the European Commission regarding the collection, use, retention, and transfer of personal data from European Union member countries, Iceland, Liechtenstein, and Norway, and from Switzerland, respectively. Walsworth commits to adhere to and has certified 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, as well as the Supplemental Privacy Shield Principles, in each case with respect to all personal data that Walsworth receives in reliance on the Privacy Shield.

Please note that the scope of Walsworth’s Privacy Shield certification excludes our processing of personal data that is done for the purposes described in paragraph (b) of the Privacy Shield’s Supplemental Principle on Journalistic Exceptions.

To learn more about the Privacy Shield, and to view Walsworth’s certification, please visit https://www.privacyshield.gov and https://www.privacyshield.gov/list, respectively.

VeraSafe Privacy Program
Walsworth is a member of the VeraSafe Privacy Program, meaning that with respect to personal data processed in the scope of this privacy policy, VeraSafe has assessed Walsworth’s data governance and data security for compliance with the VeraSafe Privacy Program Certification Criteria. The certification criteria require that participants maintain a high standard for data privacy and implement specific best practices pertaining to notice, onward transfer, choice, access, data security, data quality, recourse, and enforcement.

Dispute Resolution
Where a privacy complaint or dispute cannot be resolved through Walsworth’s internal processes, Walsworth has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Within the scope of this privacy policy, and subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Privacy Shield Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

Controllership
In the scope of this privacy policy, Walsworth acts as a joint data controller for the PII we process in the Members Only and Online Design web applications, as well as in the Mobile Apps and the Community Upload information system.

Data We Process
Data We Automatically Collect
When you access our Services, whether by computer, mobile phone or other device, we automatically collect certain data about your use of our Websites and Services using technologies such as cookies. This data may include without limitation:

  • geographical location and IDs of your computer, mobile or other device;
  • bandwidth used;
  • system and connection performance;
  • browser type and version;
  • operating system;
  • referral source;
  • length of visit;
  • page views;
  • your mobile carrier; and
  • IP address or other unique identifier for your computer, mobile phone or other device.

When you download and use our Mobile Apps, we may also collect additional data about your mobile device, including the hardware model, operating system and version, mobile network data and time zone.

This data is not linked to personal data (called “PII”) except your IP address, which may be personally identifying.

Your PII That We Process
In some situations you or someone else may provide us with your PII. Such PII could include:

  • your name;
  • street address;
  • telephone number;
  • email address;
  • photographic image that includes facial or other distinguishing characteristics; and
  • any other data we collect about you that by itself is not PII but if combined with PII could be used to personally identify you.

Your PII may be provided to us when you or someone else:

  • submits content to our Services;
  • registers for certain services, or registers an account or profile to access, visit, or use certain portions of our Services;
  • requests technical or customer support;
  • any other transactions occurring on or in relation to our Services.

Cookies
A “cookie” is a small file stored on your computer that contains data about you, your computer, or your use of our Services. By showing how and when visitors use the Services, cookies help us identify how many unique users visit us, save user preferences, and track user trends and patterns. We use session cookies, which are cookies that are deleted when you leave our Services and persistent cookies, which are cookies that remain after you leave our Services so that you are recognized when you return.

The use of cookies is industry standard so your browser may be set to accept cookies. If you would prefer not to accept cookies, you can alter the configuration of your browser to reject all cookies or some cookies. Note, if you reject certain cookies, you may not be able to access all of the features of our Services.

How We Use Your PII
Walsworth Will Use Data We Automatically Collect To:

  • improve your experience on our Services;
  • count users who open our HTML-formatted email messages;
  • improve the delivery of our Services;
  • to help us better manage content on our Services by informing us what content is effective; and by helping to measure traffic on our Services.

More specifically, Walsworth May Use IP Addresses To:

  • help diagnose problems with our web servers;
  • administer our servers;
  • analyze trends;
  • track users’ movement;
  • gather broad demographic information for aggregate use in order for us to improve the Services; and
  • deliver customized content.

Walsworth Will Use PII To:

  • Respond to your inquiries, and/or other requests or questions;
  • enable your use of the Services; and
  • print and distribute yearbooks based on behalf of, and under the instruction of, Walsworth’s client.

You may opt to receive email marketing communications relating to our business which we think may be of interest to you, email messages containing company news, product or service information, and certain email marketing communications relating to third parties such as our affiliates and/or carefully-selected third parties.

Lawful Basis of Processing
Walsworth processes PII on the basis of your consent, as provided by you to Walsworth’s client. You have the right to object to our processing of your PII done on this basis, by revoking your consent. To do this, please contact Walsworth’s client to whom you provided your consent initially.

Sharing PII with Service Providers
We may use third parties to perform certain services on our behalf. We may share your PII, including payment card information if applicable, with these third parties solely to enable them to perform the services for us.

Such third parties include those:

  • hosting our Services;
  • managing the functionality of our Services;
  • providing marketing automation or analytics software as a service;
  • providing cloud storage.

We require that those third party vendors maintain at least the same level of confidentiality, integrity, and availability that we maintain for such PII. Walsworth remains liable for the protection of your PII that we transfer to our service providers, except to the extent that we are not responsible for the event giving rise to any unauthorized or improper processing.

Other Disclosure of PII
We may disclose your PII (i) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders or (ii) if we sell or transfer all or a portion of our company’s business interests, assets (or both), or in connection with a corporate merger, consolidation, restructuring, or other company change or (iii) to our subsidiaries or affiliates only if necessary for business operational purposes.

Considering that Walsworth processes PII for purposes that include printing and distributing yearbooks on behalf of Walsworth’s clients, all PII that is submitted to the Services may be made public.

If we must disclose your PII in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your PII will maintain the privacy or security of your PII.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII, about our Services’ users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.

Except as provided in this privacy policy, we will maintain the confidentiality of PII we process.

Security
Walsworth has implemented and follows commercially reasonable measures to protect against unauthorized access to, and unlawful interception or processing of, PII. Unfortunately, data transmission over the Internet is never 100% secure so we cannot guarantee the security of any data you transmit to us or from our Websites and Services; therefore, you use our Websites and Services at your own risk.

If you register on our Websites and/or Services you are responsible for protecting the security of your username and password. You are responsible for any transaction made using your username and password.

Data Retention
PII processed in the Services is retained for as long as is necessary for us to perform our obligations under the contract entered into between Walsworth and the institution that has engaged Walsworth. PII collected via the Websites is retained for as long as we have a legitimate interest in the processing of such PII. Note that we keep backup copies of our databases as part of our disaster recovery/business continuity plans, and it may not be reasonably possible for us to delete data from such backups.

Posting In Public Areas of Our Websites
You may choose to participate in our message boards and other public areas (together “Public Spaces”) where you can engage in social networking, interact with others, and submit writings, computer graphics, pictures, questions, comments, testimonials, suggestions or other content, including PII. If there is data that you do not wish to disclose to third parties, we suggest that you not post it. Others will be able to view and access such data and they may be able to use it and share it with third parties at their sole discretion.

Testimonials
We may select and post customer testimonials on our Websites, which may contain PII such as your name and the city, state and country in which you live. We will obtain your consent prior to posting any testimonial with your name.

If you would like us to remove or delete your name or testimonial from our Websites, you may contact us at alex.blackwell@walsworth.com.

Note that copies of data that you have updated, modified, or deleted may remain viewable in cached and archived pages of our Websites for a period of time.

Third Party Websites
Our Services may contain links to third party content or websites that Walsworth does not control. This includes links from advertisers, sponsors, and partners. Please note that if you click on these links and enter a third party’s website these third parties may use their own cookies to collect data or solicit PII. You should read the third party website’s privacy policy to learn how they will collect and use your data as their policies may differ from ours and will apply to your use of their website.

Walsworth is not responsible for the treatment of your PII by these third parties.

Access, Review & Opting Out
To the extent that the Services include such ability, you may login at the applicable Walsworth Service to view, edit, or delete your PII from our records. Alternatively you may submit your request to view, edit, or delete your PII directly to the relevant Walsworth client.

You are responsible for maintaining the accuracy of the PII you submit to us, such as your contact information provided as part of registration.

Please note that if you opt out of promotional/marketing emails, you may continue to receive certain communications from us, such as administrative and services announcements and messages about your account/profile.

When you edit or delete your PII, the PII that you remove may remain in our databases or backup media because it is not always possible to completely remove or delete data from those locations. Similarly, once PII has been published in hardcopy (e.g., in yearbooks) it becomes public information and cannot be corrected, edited, or deleted from such yearbooks.

Children’s Privacy
Our Websites and Services are not directed at, or intended for use by, children under the age of 13. Children should always get permission from a parent or guardian before sending PII over the Internet. If you believe your child may have provided us with PII, you can contact the institution that has engaged Walsworth to lodge your request that the PII be deleted.

Changes to This Privacy Policy
We may update this privacy policy from time to time by posting a new version on our Websites. You should visit this page occasionally to ensure you agree with any changes. We will post our revised privacy policy on our Websites and update the “Effective Date” above to reflect the date of the changes. You are responsible for maintaining the accuracy of the PII you submit to us, such as your contact information provided as part of registration.

By continuing to use our Websites and/or Services after we post any such changes, you accept the privacy policy as modified.

Questions or Concerns, Contact Us
If you have any questions about this privacy policy or our treatment of your PII, please contact the institution that has engaged Walsworth to provide the Services, or write to our privacy officer by email at mike.sargent@walsworth.com or by postal mail at:
Attn: Director of Technology
Walsworth Publishing Company, Inc.
306 North Kansas Ave.
Marceline, MO 64658
USA

We will respond within four weeks of receiving your inquiry. If you need to communicate with us regarding your credit card or other payment information please contact us by phone at 1-800-369-2646. If you are not 13 years of age or older, you must have your parent or legal guardian’s permission to call this number.

Binding Arbitration
If your dispute or compliant can’t be resolved by VeraSafe nor through the Department of Commerce, you may have the right to require that Walsworth enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.

Regulatory Oversight
Walsworth is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.