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Arvato Digital Services LLC Online Privacy Statement

Your Privacy Rights

Valid as of: 05/14/2018

Arvato Digital Services LLC ("Arvato") is committed to the protection of personal data. This Privacy Statement describes Arvato's privacy practices in relation to the use of Arvato's websites and the related programs offered by Arvato (collectively, the "Program(s)"), as well as individuals' choices regarding use, access and correction of personal data.

Scope

Arvato provides Programs that our customers use to operate aspects of their businesses. Arvato processes data our customers submit to our services or instruct us to process on their behalf. While Arvato's customers decide what data to submit or instruct us to process, it typically includes information, including Personal Data (as defined below) about their customers (hereinafter also referred to as "you(r)"), such as contact information, purchases and billing information.

This Privacy Policy covers the information practices involved with Arvato's collection, use, sharing and securing of Personal Data collected during the management of Programs and on Program websites that link to this Privacy Policy.

Collection and processing of Personal Data

Personal Data ("Personal Data") refers to all information that identifies you, such as your name and your email address. Such data is stored if you provide it to Arvato. Our websites may also collect certain information about your visit, such as the name of the Internet service provider and the Internet Protocol (IP) address through which you access the Internet; the date and time you access our website; the pages that you access while at our website; and the Internet address of the website from which you linked directly to our website. This information is used for the operation and improvement of our websites and for the implementation of the Programs. Arvato takes reasonable and appropriate administrative, technical and physical measures to protect the confidentiality, integrity and availability of Personal Data, whether in electronic or tangible, hard copy form. Arvato takes reasonable steps to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Use and Sharing of Personal Data

Arvato will use your Personal Data for administration of the Program(s), operation of the website(s), to give you access to special information, to provide you access to certain products and services and for general communication with you.

Arvato occasionally contracts with other companies to provide limited services on our behalf. These service providers are authorized to use your Personal Data only as necessary to provide the requested services to us. We will only transfer to those companies the Personal Data they need to deliver the service.

Arvato may share Personal Data with other affiliated companies in order to work with them, including other affiliates of the Bertelsmann corporate group. For example, Arvato may need to share Personal Data on systems managed by other companies within the Bertelsmann corporate family for customer support, technical operations and account management purposes.

Personal Data will not otherwise be shared with third parties except in cases such as a court ruling in accordance with legislative harmonization, legal exceptions, exceptions mentioned in this Privacy Policy and personal approval for information sharing. In cases of forgery/fraud, investigation or information security breach, Arvato reserves the right to partner with legal authorities and reveal information (including personal) when requested by judicial authorities.

You acknowledge (a) that you are providing Personal Data to a company in the United States and (b) that we must adhere to laws of the United States. You agree that Personal Data collected on our websites may be stored and processed in the United States or any other country in which Arvato or its affiliates, providers or agents maintain facilities, and while in such jurisdiction may be subject to access pursuant to the laws of such jurisdiction.

Children's Privacy

Arvato does not target its Programs to children under 13.

Cookies and Similar Technologies

Arvato uses cookies (small text files placed on your device), tracking pixels/web beacons and other similar technologies to obtain information on your use of the Arvato websites. This information includes Internet Protocol (IP) addresses, browser type, pages viewed, links clicked and other actions you take in connection with our websites. Among other things, this makes it possible to recognize your computer automatically the next time you view the Arvato websites and to manage your access to and use of our websites. Further, we may allow third-parties, including our authorized service providers, advertising agencies and marketing partners to use tracking technologies, such as cookies and web beacons, to collect non-personal information about your visits to this and other websites. This information generally enables them to track and gauge the effectiveness of our Programs and of various marketing campaigns and in some cases to serve ads about goods and services that may be of interest to you when you visit other websites across the Internet. Depending on your settings, your Internet browser may automatically accept cookies and similar technologies. However, you may also change your browser settings at any time. Your browser settings may impact your experiences with our websites.

Right to Information

Arvato may retain your information for a period consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account to use our Programs and for a reasonable period afterward. We also may retain your information during the period needed for Arvato to pursue its legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

You may request to review, correct, delete or otherwise modify any of the Personal Data that you have previously provided to us through Arvato's websites and Programs. If you have questions concerning the processing of your Personal Data, please contact our data protection official at:

Legal Affairs Department Arvato Digital Services LLC 589 Eighth Avenue 15th FL New York, NY 10018

Upon request, you will be informed in writing, in accordance with applicable laws, as to whether and/or what Personal Data about you Arvato has stored via its website. Requests to access, change, or delete your information will be addressed within a reasonable timeframe.

Any inquiries or complaints regarding this Privacy Statement should be sent to: Privacy-NA@arvato.com

Your California Privacy Rights

California Civil Code Section 1798.83 gives California residents the right to request, from a business with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third-parties for direct marketing purposes by such third-party, and the identities of the third-parties with whom the business has shared such information during the immediately preceding year. To request further information pursuant to California Civil Code Section 1798.83, please contact us at the address listed above.

Notification of changes

This Privacy Policy may be amended from time to time consistent with changes in our business or Programs. Appropriate notice regarding such amendments will be given. This Privacy Policy is binding between Arvato and its visitors.