EU-U.S. Privacy Shield Framework
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.
VeraSafe Privacy Program
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. 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/
Data We Process
Data We Automatically Collect
When you access our Websites or 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. PII could include:
- your name;
- street address;
- telephone number;
- email address;
- photographic image that includes facial or other distinguishing characteristics;
- credit card and/or other payment/ordering information; 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:
- makes a purchase on the Websites;
- submits content to our Services;
- subscribes to Walsworth’s email notifications or newsletters;
- registers for certain services, or registers an account or profile to access, visit, or use certain portions of our Websites or Services;
- requests technical or customer support;
- provides comments and/or reviews on or about our Websites, products, or Services; and
- any other transactions occurring on or in relation to our Websites or Services.
How We Use Your PII
Walsworth Will Use Data We Automatically Collect To:
- improve your experience on our Websites and our Services;
- to count users who open our HTML-formatted email messages;
- improve the delivery of our web pages;
- to help us better manage content on our Websites by informing us what content is effective; and
- by helping to measure traffic on our Websites and Services.
More specifically, Walsworth May Use IP Addresses To:
- help diagnose problems with our web servers;
- administer our web servers;
- analyze trends;
- track users’ movement;
- gather broad demographic information for aggregate use in order for us to improve the Websites and 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;
- print and distribute yearbooks based on behalf of, and under the instruction of, Walsworth’s institutional customers;
- track yearbook sales;
- contact you regarding your purchase;
- collect payments from you; and
- send you goods or services purchased through our Websites, information and updates related to your purchase, invoices and email notifications which you have specifically requested.
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 the pursuit of our legitimate interests. You have the right to object to our processing of your PII done on this basis. Refer to the section on Access, Review & Opting Out for specific instructions.
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 Websites or Services;
- managing the functionality of our Websites or Services;
- providing CRM software as a service;
- providing survey software as a service;
- providing marketing automation or analytics software as a service;
- providing cloud storage;
- processing credit or other payment card payments;
- providing live chat software as a service;
- fulfilling and processing orders;
- delivering products you have ordered;
- assisting with promotions; and
- enabling us to send you email.
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 Waslworth’s institutional customers, 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 Websites’ and Services’ users as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients and customers.
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.
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.
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 email@example.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
Walsworth is not responsible for the treatment of your PII or any of your data by these third parties.
Access, Review & Opting Out
You may login at the applicable Walsworth Website or Service to view, edit or delete your PII from our records. If your PII processed in the Services has not yet been printed in a yearbook, you may opt out of having your PII shared with third parties (except as required by law) by deleting your PII from the Services. Alternatively you may submit your request to view, edit or delete your PII directly to the institution that has engaged Walsworth to provide the Services.
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 a yearbook) it becomes public and cannot be deleted or edited.
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.
Questions or Concerns, Contact Us
Attn: Director of Technology
Walsworth Publishing Company, Inc.
306 North Kansas Ave.
Marceline, MO 64658
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.
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.
Walsworth is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.