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I. GeneralValassis respects the privacy of every individual who visits our website. This Privacy Statement outlines the information Valassis will collect and how we will use that information. This Statement will also instruct you on how you can verify the accuracy of your personally identifiable information submitted to Valassis through our website and how you can request that we delete your personally identifiable information from our databases.
II. Personally Identifiable InformationWhen you visit Valassis's website, we will not collect any personally identifiable information about you (such as your name, address, telephone number, or e-mail address) unless you provide it to us voluntarily.
III. Use of Personally Identifiable InformationWe may request that you voluntarily supply us with personal information, including your e-mail address, postal address, home or work telephone number for purposes such as correspondence, surveys or games. If you choose to give us personal information via the Internet that we or our business partners may need to correspond with you, it is our intent to let you know how we will use such information.
Valassis may store and process your personally identifiable information to better understand your needs and how we may improve our products and services, and we may use your personally identifiable information to contact you. Valassis will not give or sell your personally identifiable information to any outside organization for the organization's own use without your consent, unless required to be disclosed by law or court order. Your information may be shared with agents or contractors of Valassis in connection with services that these individuals or entities perform for Valassis.
IV. Security Valassis is committed to keeping secure the data you provide us and will take reasonable precautions to protect your personally identifiable information from loss, misuse or alteration. Agents or contractors of Valassis who have access to your personally identifiable information in connection with providing services for Valassis are required to keep the information confidential and are not permitted to use this information for any other purpose than to carry out the services they are performing for Valassis.
V. Non-Personally-Identifiable Information Collected Automatically In some cases, we may collect information about you that is not personally identifiable. Examples of this type of information include the type of Internet browser or computer operating system you are using and the domain name of the website from which you linked to our site. In addition, when you view our website, we may store some information on your computer. This information will be in the form of a "cookie" or similar file and will help us in many ways. A cookie cannot retrieve any other data from your hard drive, pass on a computer virus, or capture your e-mail address. For example, cookies allow us to tailor a website or advertisement to better match your interests and preferences. Cookies can securely store a user's password, personalize home pages, and identify which parts of a site have been visited.
Safe Harbor Privacy Statement
Safe Harbor Compliancy Affirmative Statement for U.S.-E.U and U.S.-Swiss FrameworksValassis Communications, Inc. complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Valassis has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Valassis's certification, please visit http://www.export.gov/safeharbor
ScopeThe U.S. Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the U.S.-EU Safe Harbor Framework) to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. The U.S. Department of Commerce and the Federal Data Protection and Information Commissioner of Switzerland have agreed on a similar set of data protection principles and frequently asked questions (the U.S.-Swiss Safe Harbor Framework). Consistent with its commitment to protect personal privacy, the Company adheres to the respective Safe Harbor Principles. The Policy applies to all personal information received by the Company in the United States from the European Union and Switzerland. For additional information regarding the Safe Harbor Program, see the U.S. Dept. of Commerce web site at http://www.export.gov/safeharbor.
Privacy PrinciplesThe privacy principles in this Policy are based on the Safe Harbor Principles.
NoticeWhere the Company collects personal information directly from individuals in the EU and Switzerland, it will inform them about the type of personal information collected, the purposes for which it collects and uses the personal information, and the types of non-agent third parties to which the Company discloses or may disclose that information to, and the choices and means, if any, the Company offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to the Company, or as soon as practicable thereafter, and in any event before the Company uses or discloses the information for a purpose other than that for which it was originally collected.
ChoiceThe Company will offer individuals the opportunity to choose (opt-out) whether their personal information is to be disclosed to a non-agent third party or to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.For sensitive personal information, the Company will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
Onward TransferThe Company only transfers Personal Data to a service provider, vendor or other third party acting as a processor of Personal Data for the Company (an "agent") where the agent has provided assurances that said agent provides at least the same level of privacy protection as is required by these privacy principles. Where the Company has knowledge that one of its agents is using or sharing Personal Data in a way that is contrary to these principles, the Company will take reasonable and appropriate steps to prevent or stop such processing. The Company will only transfer Personal Data to a non-agent third party where such transfer is consistent with applicable laws and with the notice provided to the data owners at the time the Personal Data were collected.
Security The Company takes reasonable precautions to protect EU and Swiss Personal Data in its possession to prevent loss, misuse, disclosure, unauthorized access, alteration or destruction.
Data Integrity Personal information collected will only be processed in a way that is compatible and relevant for the purposes for which it is to be used. To the extent necessary for those purposes, the Company will take reasonable steps to ensure the data is accurate, complete, current and reliable for its intended use.
AccessUpon request, data subjects will have access to their EU or Swiss Personal Data held by the Company and may correct, amend, or delete their Personal Data if it is inaccurate. However, access to such EU or Swiss Personal Data may be denied, when the burden or expense of providing access would be disproportionate to the risks to the data subject's privacy in the case in question, or where the rights of persons other than the data subjects would be violated.
EnforcementThe Company will internally assess the Policies and their practices to ensure continuous compliance with the Safe Harbor frameworks. Any Company employee found to have violated the privacy principles in this Safe Harbor Statement will be subject to appropriate corrective actions up to and including termination of employment.
Dispute ResolutionAny questions or concerns regarding the use or disclosure of personal information should be directed to the Companies' Privacy Office at the address given below. The Company will investigate and attempt to resolve complaints and disputes regarding use or disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between the Company and the complainant, the Company has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles, and to cooperate and comply with the Federal Data Protection and Information Commissioner of Switzerland.
Changes to this Privacy StatementThis privacy statement may be amended consistent with the requirements of Safe Harbor. When we do update the privacy statement, we will also revise the last updated date at the bottom of this document. Any material changes to this privacy statement will also be posted on the company's website www.valassis.com.
Last Updated: June 17, 2011
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