The Jonathan Radford Privacy Policy

Effective January 1, 2018

1. INTRODUCTION

Jonathan Radford wants you to be familiar with how we collect, use and disclose information from and about you because we understand you are concerned about your privacy, and we want to maintain your trust.

This Privacy Policy applies to information we collect from all sources including in connection with our websites, mobile sites, applications ("apps"), electronic newsletters and widgets that link to this Privacy Policy.

This Policy describes Jonathan Radford’s collection and use of users' Personal Information. It also describes generally Jonathan Radford's practices for handling Other Information (e.g., interests, demographics and services usage) collected through Jonathan Radford’s website or from a third party to the extent such information is associated with a particular device, user or user account. By using Jonathan Radford’s website or by providing personal information to us, you agree to the terms and conditions of this Privacy Policy.

You may choose not to submit requested information online, or may choose to restrict the use of cookies (see Other Information below, or our Cookie Policy, for more information), but that may limit the services Jonathan Radford is able to provide to you.

Jonathan Radford website is a network of general audience sites, and is not targeted to, and do not knowingly collect Personal Information from, minors under 18 years of age. We request that these individuals do not provide Personal Information through Jonathan Radford website. 2. INFORMATION WE COLLECT

Jonathan Radford and our service providers may collect the following information from and about you:

PERSONAL INFORMATION

"Personal Information" for purposes of this Privacy Policy is the information that identifies you as an individual or relates to an identifiable person, such as name, postal address (including shipping addresses), telephone number, email address or profile picture.

PERSONAL INFORMATION FROM YOU

We collect Personal Information when, for example, you register for or subscribe to certain products or services; request newsletters; take a survey; visit Jonathan Radford website; use an interactive feature (such as Chat or Email This); participate in a community forum; or contact customer service.

PERSONAL INFORMATION WE RECEIVE FROM THIRD PARTIES

We may receive Personal Information about you from third parties, such as social media services, commercially available sources, Jonathan Radford Affiliates, business partners, and, if applicable to you, the third-party provider of your subscription. The Personal Information we receive from third parties may include, for example, your name, relationships with various product and service providers, and your use of certain applications. For example, if you access Jonathan Radford website through a social media service or connect Jonathan Radford website to a social media service, the information we collect may also include your user name associated with that social media service, any information or content the social media service has the right to share with us, such as your profile picture, email address or friends list, and any information you have made public in connection with that social media service. When you access the Jonathan Radford website through social media services or when you connect Jonathan Radford website to social media services, you are authorizing Jonathan Radford to collect, store, and use such information and content in accordance with this Privacy Policy.

OTHER INFORMATION

"Other Information" is any information that does not reveal your specific identity, such as browser information, app usage data, information collected through cookies and other technologies, demographic information, and aggregated information.

OTHER INFORMATION YOU SUBMIT

We collect Other Information when you submit it to us. It may include your gender, zip code, birthday, education, occupation, financial information (such as your income, investments, portfolio transactions and value, and other information), and interests.

OTHER INFORMATION WE RECEIVE FROM THIRD PARTIES

We may receive Other Information about you from third parties, including, for example, demographic data, social media account number, information about your interests, and information about your activities on other websites.

OTHER INFORMATION WE COLLECT AUTOMATICALLY WHEN YOU ARE ONLINE

When you access and interact with Jonathan Radford website, we and our service providers may automatically collect certain information about those visits. For example, in order to permit your connection to the Jonathan Radford website, our servers receive and record information about your computer, device, and browser, potentially including your IP address, browser type, and other software or hardware information. If you access the Jonathan Radford website from a mobile or other device, we may collect a unique device identifier assigned to that device ("UDID"), geolocation data, or other transactional information for that device. Jonathan Radford and our service providers also may use cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology including cookies) when you visit or use the Jonathan Radford website. Third parties that support the Jonathan Radford website by serving advertisements or providing services, such as providing users with the ability to comment on content, allowing users to share content, customizing content based on usage, or tracking aggregate site usage statistics, may also use these technologies to collect Other Information on the Jonathan Radford website and on other websites. Please see the Jonathan Radford Cookie Policy here for more information about our use of these technologies and your choices in connection with these practices. Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g.,http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies).

You can manage the use of Flash technologies with the Flash management tools available at Adobe's website,http://www.adobe.com/devnet/security.edu.html. Please note that by blocking any or all cookies you may not have access to certain features.

3. HOW WE USE YOUR INFORMATION

We use the Personal Information we collect from and about you for the purposes set forth below. Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for all the purposes for which we use and disclose Personal Information. We may combine Other Information with your Personal Information, and when we do, we treat the combined information as Personal Information.

To improve the quality of our products and services and to personalize your experience by presenting content, products and offers tailored to you, we may also combine the Personal and Other Information we collect with information relating to your use of other Jonathan Radford products, services and websites. In addition, we may supplement the Personal and Other Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from Jonathan Radford Affiliates or business partners.

TO PROVIDE AND MANAGE OUR SERVICES. We use the information we collect from and about you to provide our products, services and features to you, including: to process and fulfill your subscription, to send you information about your relationship or transactions with us, to measure and improve those services and features, to allow you to comment on content and participate in online games, contests, promotions or rewards programs, use collaboration tools to share content and collaborate with other users, to provide you with customer support, including online chats, and to respond to inquiries. If you choose to use the collaboration tools, some of your Personal Information may be included in a directory that can be viewed and used by other users of these collaboration tools. In addition, if you have multiple product subscriptions, we may use your information to allow you to sign in to several Jonathan Radford websites with the same user ID.

TO DELIVER RELEVANT CONTENT AND RECOMMENDATIONS. To make your experience more interesting and personalized, we may use any of the Personal and Other Information we collect to assist us in delivering content on any of our Jonathan Radford website. TO DELIVER RELEVANT ONLINE ADVERTISING. The Jonathan Radford website and our service providers may use any of the information we collect from and about you (in certain cases, such as with respect to financial information, only with your express permission) to assist us in delivering relevant ads to you when you use the Jonathan Radford website or another service provided by Jonathan Radford, Jonathan Radford Affiliates, or unaffiliated third parties. (See Information We Collect, above, for details on the types of information we may use.) As noted above, we may work with third party online advertising companies and advertisers who help deliver these ads to you. These third parties may collect and use information about your activities on our Jonathan Radford website and on other websites, and Other Information about you, to limit the online ads you encounter to those we believe are consistent with your interests.

TO ALLOW SOCIAL SHARING FUNCTIONALITY. If you log in with or connect a social media service account with a Jonathan Radford website, we may use Personal and Other Information to facilitate your sharing of information between the Jonathan Radford website and your social media service.

TO CONTACT YOU. Jonathan Radford and Jonathan Radford Affiliates may periodically send promotional materials, surveys, or notifications related to our products and services. To help make these materials more relevant to you, we may use and combine any of the Personal and Other Information we collect to assist us in sending you these materials. We may also use your information to contact you, including to respond to your comments, inquiries or requests. If you want to stop receiving these materials from us, please follow the instructions in the Choices and Access section below.

TO PROTECT THE RIGHTS OF JONATHAN RADFORD AND OTHERS. Jonathan Radford may use your Personal Information as we believe to be necessary or appropriate in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Jonathan Radford, our Jonathan Radford Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of our products and services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process, including laws outside your country of residence; or (v) to respond to requests from public and government authorities including public and government authorities outside your country of residence.

4. HOW WE SHARE YOUR INFORMATION

INFORMATION MADE PUBLIC THROUGH USE OF OUR SERVICES AND USER PRIVACY SETTINGS

Certain features on the Jonathan Radford website give you an opportunity to interact with us and others. These may include the collaboration tools, community forums, chats, submitting a letter to the editor, creating community profiles, and rating, tagging and commenting on articles. When you use these features, you should be aware that any information you submit, including your name, user name, location, email address, profile information, picture, likes, status, and comments, including any political or religious or other beliefs you express, may be publicly available to anyone, including other users, search engines, advertisers, third party application developers, and anyone else with access to the Jonathan Radford website. We are not responsible for any information you choose to submit and make public through these interactive features.

OUR DISCLOSURE OF INFORMATION

Jonathan Radford and its subsidiaries may share your Personal Information with one another, for the purposes described in this Privacy Policy, including for each company's marketing purposes. Users who visit Jonathan Radford Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy. Jonathan Radford is the party responsible for the management of the jointly-used Personal Information.

In addition, we may share your Personal Information with non-affiliated third parties when sharing is permitted by you or authorized by this Privacy Policy, including: TO ALLOW THIRD-PARTY SERVICE PROVIDERS TO ASSIST US IN PROVIDING AND MANAGING OUR SERVICES. We may make your Personal Information available to certain third-party service providers, such as contractors, agents or sponsors, who help us manage or provide our products and services by, for example: developing or supporting products and features; sending email messages on our behalf; processing payments; fulfilling orders; delivering subscriptions; auditing; processing data or statistics; and serving, customizing or delivering marketing or ads. These outside service providers are required to protect Personal Information entrusted to them and not use it for any other purpose than the specific service they are providing to us.

TO PROVIDE CO-BRANDED SERVICES AND FEATURES. We may offer co-branded services or features, such as conferences, contests, sweepstakes or other promotions together with a third party ("Co-Branded Services"). These Co-Branded Services may be hosted on the Jonathan Radford website or on the third party's service. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. The third party's use of your information will be governed by the third party's privacy policy.

TO PERMIT UNAFFILIATED THIRD PARTIES TO SEND YOU PROMOTIONAL MATERIALS.

We may share your contact information with unaffiliated companies whose products and services may be of interest to you. While many of our subscribers appreciate receiving offerings from these companies, if you prefer that we do not share your information for this purpose, please contact Customer Service as described below in Choices and Access. If you subscribe solely to any other Jonathan Radford website, we may share your Personal Information with unaffiliated third parties for such parties' own marketing purposes only if you have given us permission to do so.

TO ALLOW SOCIAL SHARING FUNCTIONALITY. If you log in with or connect a social media service account with a Jonathan Radford website, we may share your user name, picture, and likes, as well as your activities and comments with other Jonathan Radford website users and with your friends associated with your social media service. We may also share the same information with the social media service provider. By logging in with or connecting your Jonathan Radford website account and your social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users and your friends, and you understand that the social media service's use of the shared information will be governed by the social media service's privacy policy. If you do not want your Personal Information shared in this way, please do not connect your social media service account with your Jonathan Radford website account, and do not participate in social sharing on the Jonathan Radford website.

TO PROTECT THE RIGHTS OF JONATHAN RADFORD AND OTHERS. There may be instances when Jonathan Radford may disclose your Personal Information, including situations where we have a good faith belief that such disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Jonathan Radford, our Jonathan Radford Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of our products and services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process, including laws outside your country of residence; or (v) to respond to requests from public and government authorities including public and government authorities outside your country of residence.

TO COMPLETE A MERGER, SALE OF ASSETS, OR BANKRUPTCY. If Jonathan Radford sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger, bankruptcy, or transfer of all or a material part of its business, Jonathan Radford may transfer your information to the party or parties involved in the transaction as part of that transaction.

5. SECURITY

Jonathan Radford uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Information in its possession against loss, theft and unauthorized use, disclosure or modification. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting Customer Service in accordance with the instructions below.

6. HOW TO ACCESS, CORRECT OR UPDATE YOUR INFORMATION

YOUR CHOICES REGARDING OUR USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION

We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes.

YOU MAY OPT-OUT from receiving electronic communications from us (including surveys or notifications), or our sharing of your Personal Information with Jonathan Radford Affiliates for their direct marketing purposes by changing your account settings through the appropriate link on the website account services page or following the unsubscribe instructions at the bottom of each email.

YOU MAY ALSO OPT-OUT from our sharing of your contact information with unaffiliated third parties for their marketing (which only applies if you are a print subscriber) by contacting Customer Service as detailed below.

Please note that there are certain service notifications that you may not opt-out of, such as renewal notices and notifications of changes to Jonathan Radford products and services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.

HOW TO ACCESS, CORRECT OR UPDATE YOUR PERSONAL INFORMATION

You can access, review, correct, update, delete or modify your registration or subscription profile information and modify your marketing preferences by contacting Customer Service, as indicated below. Most subscribers and registered users can also update their Personal Information online by signing on to their accounts and visiting the appropriate account management sections of our websites. Please note that if you have subscribed or registered for our print and online editions, or for more than one of our publications or services, you may need to update your information for each separately.

You may also contact Jonathan Radford Customer Service at jonathan@jonathanradford.com or by calling (617) 335-1010.

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). Your California Privacy Rights

California Law permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. To make such a request, please write to us at Jonathan Radford Attn: DM Disclosure Manager and include your name and the address to which you would like us to respond.

7. OTHER IMPORTANT INFORMATION

UPDATES TO PRIVACY POLICY. Jonathan Radford may modify this Privacy Policy. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Jonathan Radford website. Your use of the Jonathan Radford website or your provision of personal information to us following these changes means that you accept the revised Privacy Policy.

DO NOT TRACK DISCLOSURE. Some browsers or other tools include “Do Not Track” (DNT) features which, when turned on, send a signal to websites you visit indicating that you do not wish to be tracked across websites over time. The Worldwide Web Consortium (W3C) has been working with industry groups and regulators to develop a DNT browser technology standard to provide a common understanding as to how to interpret the DNT signals, but to date no standard has been adopted. Since there is no standard at this time, Jonathan Radford does not currently respond to DNT signals. Jonathan Radford will follow the progress of the W3C in developing the standard.

LOCATION OF DATA. Your Personal Information may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers, and by using our products and services, you consent to the processing and transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than in your country.

DATA RETENTION. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

COLLECTION OF PERSONAL FINANCIAL INFORMATION BY A PAYMENT SERVICE. In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment in such a case, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.

LINKED SERVICES. The Jonathan Radford website may also be linked to sites operated by third parties, and may carry advertisements or offer content, special offers, functionality, games or applications developed and maintained by third parties. Some of these third-party sites may be co-branded with a Jonathan Radford logo, even though they are not operated or maintained by us. For example:

Jonathan Radford is not responsible for the privacy practices of any such third parties, and once you leave the Jonathan Radford website or click an advertisement, or sign up for a special offer, you should check the applicable privacy policy of the other service.

8. CONTACT US

If you have questions about this Privacy Policy, please contact us at jonathan@jonathanradford.com.

We ask that you not disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) when contacting us.

JONATHAN RADFORD COOKIE POLICY

When you visit, access, or use the website, mobile site, application, electronic newsletter or widget that links to this Cookie Policy (collectively "Site") Jonathan Radford and its subsidiaries ("Jonathan Radford," "us," or "we") use cookies and other tracking technologies to deliver and improve the Site, and to display relevant content, products, services and advertising.

This Cookie Policy explains these technologies, including cookies, pixels, web beacons, and flash cookies, and how you can control them.

By using the Site, you agree that we can use these technologies as described in this Cookie Policy. We hope that this Cookie Policy helps you understand, and feel more confident about, our use of cookies and other tracking technologies. If you have any further queries or requests, please contact us at jonathan@jonathanradford.com.

We may change this Cookie Policy at any time. Please take a look at the Last Revised date at the top of this page to see when this Cookie Policy was last revised. Any changes in this Cookie Policy will become effective when we make the revised Cookie Policy available on or through the Site.

1. WHAT IS A COOKIE?

Cookies are small text files that are stored on your computer or mobile device. They are widely used in order to make websites work, or work in a better, more efficient way. For example, they can recognize you and remember important information that will make your use of a website more convenient (e.g., by remembering your user preferences).

2. WHAT COOKIES DO WE USE?

Below we list the different types of cookies we may use on the Site. We may also use cookies and similar tools to relate your use of the Site to personal information obtained about you. For example, if you have asked us to provide you information about our upcoming products or promotions, cookie and/or clickstream data about your activities on the Site may allow us to limit the materials we provide you to items we think you will find interesting, based on your prior online activities and preferences.

STRICTLY NECESSARY COOKIES.

These cookies are essential to the Site in order to facilitate our log-in process and enable you to move around it and to use its features. Without these cookies, we may not be able to provide certain services or features, and the Site will not perform as smoothly for you as we would like.

FUNCTIONALITY COOKIES.

In some circumstances, we may use functionality cookies. Functionality cookies allow us to remember the choices you make while browsing the Site, and to provide enhanced and more personalized content and features, such as customizing a certain webpage, remembering if we have asked you to participate in a promotion and for other services you request, like watching a video or commenting on a blog. In order to permit your connection to the Site, our servers receive and record information about your computer, device, and browser, potentially including your IP address, browser type, and other software or hardware information. If you access the Site from a mobile or other device, we may collect a unique device identifier assigned to that device ("UDID"), geolocation data, or other transactional information for that device. All of these features help us to improve your visit to the Site.

FLASH COOKIES.

We may, in certain situations, use Adobe Flash Player to deliver special content, such as video clips or animation. To improve your user experience, Local Shared Objects (commonly known as “Flash cookies”) are employed to provide functions such as remembering your settings and preferences. Flash cookies are stored on your device, but they are managed through an interface different from the one provided by your web browser. This means it is not possible to manage Flash cookies at the browser level, in the same way you would manage cookies. Instead, you can access your Flash management tools from Adobe’s website directly. The Adobe website provides comprehensive information on how to delete or disable Flash cookies - seehttp://www.adobe.com/security/flashplayer for further information. Please be aware that if you disable or reject Flash cookies for this Site, you may not be able to access certain features, such as video content or services that require you to sign in.

ANALYTICS COOKIES.

We and our service providers may use analytics cookies, which are sometimes called performance cookies, to collect information about your use of the Site and enable us to improve the way it works. Analytics cookies collect information about how you use the Site, for instance, which pages you go to most. The information allows us to see the overall patterns of usage on the Site, help us record any difficulties you have with the Site and show us whether our advertising is effective or not.

ADVERTISING COOKIES.

We and our service providers may use advertising cookies to deliver ads that we believe are more relevant to you and your interests. For example, we may use targeting or advertising cookies to customize the advertising and content you receive on our Site, to limit the number of times you see the same ad on our Site and to help measure the effectiveness of our advertising campaigns. These cookies remember what you have looked at on the Site and other sites, and may be combined with other information acquired from third parties, and we may share this information with other organizations, such as advertisers.

For more information about targeting and advertising cookies and how you can opt out, visit:

Network Advertising Initiative: http://www.networkadvertising.org/choices/ Digital Advertising Alliance: http://www.aboutads.info/choices/ European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu/ http://www.youronlinechoices.com/uk/your-ad-choices

SOCIAL NETWORKING COOKIES.

These Social plug-in tracking cookies can be used to track both members and non-members of social networks for "additional" purposes such as behavioural advertising, analytics, and market research.

Cookie Name	Further information
Facebook Social Plugin	http://www.facebook.com/help/www/443483272359009
Google Plus	https://support.google.com/plus/#topic=3049735
LinkedIn	http://www.linkedin.com/legal/privacy-policy
Twitter	https://twitter.com/privacy
YouTube	http://www.youtube.com/t/interest_based_ads

3. HOW DO THIRD PARTIES USE COOKIES ON THE SITE?

In some circumstances, we may work with third parties to provide services on our Site. For example, we use analytics services supported by third party companies who generate analytics cookies on our behalf. We may not have access to these cookies, although we may use statistical information arising from the cookies provided by these third parties to customize content and for the other purposes described above. These companies may also transfer this information to other parties where required to do so by law, or where such other parties process the information on their behalf.

Third-party advertisers and other organizations may also use their own cookies to collect information about your activities on our Site and/or the advertisements you have clicked on. This information, which may be combined with other information acquired from third parties, may be used by them to serve advertisements on our Site and third party sites that they believe are most likely to be of interest to you based on content you have viewed. Third-party advertisers may also use this information to measure the effectiveness of their advertisements and to track aggregate usage statistics.

We may not control these third-party cookies and their use may be governed by the privacy policies of the third parties employing these cookies. To learn about these cookies and to disable or reject third-party cookies, please refer to the relevant third party’s website. For more information about third-party advertising on the Jonathan Radford website, see the section on delivering advertising in the Privacy Policy . To find out more about third-party online advertising and to opt out of this type of advertising, please see the Advertising Cookies section above.

You can also learn more about controlling cookies in section 4 below.

4. HOW CAN YOU CONTROL COOKIES?

You may refuse to accept cookies from the Site at any time by activating the setting on your browser, which allows you to refuse cookies. You can refuse to accept Flash cookies from the Site using Adobe’s Flash management tools athttp://www.adobe.com/security/flashplayer. Further information about the procedure to follow in order to disable cookies can be found on your Internet browser provider’s website via your help screen. You may wish to refer tohttp://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers.

Please note that by disabling or blocking any or all cookies, some features of the Site may not operate as intended, or you may not have access to features or personalization available through the Site.

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