VANCE PUBLISHING CORPORATION

WEB SITE PRIVACY POLICY

(Effective May 1, 2009)

This web site privacy policy (“Privacy Policy”) is provided by Vance Publishing Corporation and its affiliates, subsidiaries and related entities (“Vance,” “we,” “our” or “us”).  This Privacy Policy describes Vance's practices regarding Personal Information collected via the Vance web sites that include a link to this Privacy Policy (the “Web Sites”).  Unless specifically stated otherwise, this Privacy Policy applies only to Personal Information that we gather or collect via such Web Sites.  It does not apply to any information collected offline or otherwise outside of the Web Sites.

Please take a moment to review the terms of this Privacy Policy.  Please also review our Terms of Use, which govern your use of our Web Sites.  Please note that certain features or services discussed in this Privacy Policy may not be offered or available on all of the Web Sites.

1.   THE INFORMATION WE MAY COLLECT

When you visit a Web Site we may collect two types of information from you: (1) Personal Information you voluntarily choose to disclose to us, and (2) Web Site Usage Information that we automatically collect as you interact with the Web Site.

(a)  Information You Voluntarily Provide to Us

In most cases you can visit a Web Site without telling us who you are and without giving any information about yourself.  The only exceptions are those Web Sites that require you log in with a userID and password in order to access the Site.  There are times, however, when we may ask you to voluntarily provide information about yourself, such as your name, mailing address, e-mail address, phone number, gender, credit or debit card number, hobbies, preferences, interests, etc. ("Personal Information"). For example, we may ask you to give us Personal Information so that we can register you with a Web Site, provide you with a subscription to a newsletter, process an order you submit, provide a service to you, or so that we may correspond with you.  In addition, there are certain other situations where we may collect and use Personal Information that you voluntarily provide while using a Web Site even though it is not necessary for the function you are using.  This includes, for example, Personal Information you provide when you use community features such as blogs, chat, message boards and other types of public forums, when you provide submissions to us or a Web Site, or when you use the “contact us” mechanisms.  You are under no obligation to provide such Personal Information, but if you chose not to you may be unable to use certain features or services provided by the Web Sites.

(b)  Information We Automatically Collect

When you visit a Web Site, we automatically collect certain information related to your activities on the Web Site (“Web Site Usage Information”).  This information may include your browser type and operating system, the domain from which you came, the page you are viewing, the time, and what you clicked on, among other information.  In addition, your IP address or some other unique identifier for the particular device you use to access the Internet, as applicable (collectively referred to as a "Device Identifier") may be collected.  A Device Identifier is a number that is automatically assigned to your computer, your cell phone, or other device you use to access the Internet, and our computers identify your device by its Device Identifier. 

To collect Web Site Usage Information, we may utilize a variety of technologies such as cookies, web beacons, embedded scripts or similar technologies.

·         Cookies.  A cookie is a data file placed on a computer when it is used to visit a Web Site.  Cookies may be used for many purposes, such as tracking user preferences and web pages visited while using the Web Site.  You may disable cookies using your browser's preferences, but some features of the Web Site may not function properly or may operate slowly if you disable the cookies.

·         Web Beacons.  Small graphic images or other web programming code called web beacons, (also known as "1x1 GIFs" or "clear GIFs,)" may be included in our web pages and e-mail messages.  Web beacons or similar technologies may be used for a number of purposes, such as to count visitors to the Web Site, to monitor how users navigate the Web Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

·         Embedded Scripts.  An embedded script is programming code that is designed to collect information about your interactions with the Web Site, such as which links you click on.  The code is temporarily downloaded onto your computer from our web server or a third party service provider, is active only while you are connected to the Web Site, and is deactivated or deleted thereafter. 

The Web Site Usage Information we collect may be used for a number of purposes, such as system administration, to help us understand the demographics of the visitors to the Web Sites, to enhance the performance and usefulness of the Web Sites, to report aggregate information to our business partners, or to audit use of the Web Sites.  Web Site Usage Information is typically anonymous information, since it is not normally associated with you or your identity.  However, if it is combined with your Personal Information in a manner that it is directly associated with your identity it will be treated as Personal Information under this Privacy Policy.

2.   USE OF PERSONAL INFORMATION

We may retain and use Personal Information collected from the Web Sites for a variety of purposes, including: (1) to provide you with information or services, or to process transactions, that you have requested or agreed to receive; (2) to process your registration with a Web Site, including verifying that your e-mail address is active and valid; (3) to improve the Web Sites or our services, or to customize your experience on the Web Sites; (4) to communicate with you regarding information, features, products, services, or offers that we believe may be of interest to you; (5) to respond to your questions or other requests; (6) to contact you with regard to a Web Site; (7) to process any applications, orders, payments, or changes to your account information; (8) to process Personal Information or other information that you submit through a Web Site; (9) to conduct user surveys; (10) to contact you regarding a sweepstakes, contest or promotion in which you have participated, (11) for internal business purposes; and (12) for other purposes disclosed in this Privacy Policy, at the time you provide the Personal Information, or thereafter.  We may also use the information you provide to improve the Web Sites or our services, to customize your experience on the Web Sites, to serve you specific content, or for other business purposes.  

3.   SHARING OF PERSONAL INFORMATION WITH THIRD PARTIES

Affiliated or Subsidiary Companies. We may share Personal Information with our affiliated or subsidiary companies.

Third Party Marketing.  We may share Personal Information with unaffiliated third parties for those third parties' marketing purposes unless you tell us not to by opting out of such sharing.  You may tell us not to share Personal Information by using the process available on the Web Site at the time you provide your Personal Information or thereafter by following the procedures available on the Web Site, or contacting us at the address listed below.      

Sweepstakes, Contests and Promotions.  We may offer sweepstakes, contests, and other promotions (collectively, "Promotions") through the Web Sites.  If you choose to enter a Promotion, Personal Information about you may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.  Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion.

Third parties providing services on our behalf.   We may share your Personal Information with third parties who perform services on our behalf.  This includes, without limitation, third parties that host one or more of the Web Sites or operate certain functions or features of one or more of the Web Sites, send communications (including marketing e-mails), process credit card and other payment transactions, fulfill orders, analyze data, provide marketing assistance, or create, host and/or provide customer service on our behalf.  These third parties may have access to Personal information in order to provide these services to us or on our behalf.

Business Transfers and Corporate Changes.  Vance reserves the right to disclose and transfer all information related to the Web Sites, including Personal Information: (i) to a subsequent owner, co-owner or operator of one or more of the Web Sites; or (ii) in connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of Vance's stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.

Legal Requirements and Law Enforcement.  We may also transfer and disclose information, including Personal Information, to third parties: (i) in the event we are required to respond to a court order, subpoena, discovery request, or other legal process, or if in our good faith opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an audit or investigation; (iii) to verify or enforce compliance with our Terms of Use, other agreements or policies governing a Web Site, or applicable laws, rules, and regulations; or (iv) whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of a Web Site, its users or other third parties.  We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.

Sharing of Non-Personal Information.  We may share non-personally identifiable information, such as Web Site Usage Information or other aggregated user statistics, as well as anonymous information derived from Personal Information, such as de-identified user information, with third parties for any purpose.

4.   SPECIAL SITUATIONS

Information You Provide Through Community Features.  Our Web Sites may include various community features, including, blogs, message boards and other types of public forums, as well as offer users the ability to interact with others through social networking features.  You may also have the opportunity to create a personal profile that may include information such as your contact information and profession ("Profile"), and to choose whether to share certain aspects of your Profile with the public or other visitors to the Web Site.  This Privacy Policy does not apply to any information that you disclose publicly or otherwise upload onto your Profile that is disclosed publicly.  If you post Personal Information through a community functionality offered on a Web Site, it will be publicly available and you may receive unsolicited messages from other parties.  Vance cannot ensure the security of any information you choose to make public and cannot ensure that parties who have access to such publicly available information will respect your privacy.  Please exercise caution when deciding what information to include in your Profile and when deciding to disclose Personal Information in any public areas of the Web Sites.

Information You Provide Through Submissions.  If you submit ideas, votes, comments, reviews, suggestions, photographs, text or other content (collectively, "Submissions") to a Web Site, they may be published online or offline in any media or format (currently existing or hereafter developed).  Others may have access to your Submissions and may have the ability to share them with third parties across the Internet.  Vance may also publish your name, voice, likeness and other Personal Information with the Submissions (or any portion thereof), and Vance may use the Submissions, in whole or in part, for advertising, marketing, publicity and promotional activities.  For full terms and conditions regarding our Submissions Policy, please review the Site's Terms of Use.

Information You Provide to Third Parties via a Web Site.  In some cases, a Web Site may include third party information collection forms, and any information submitted via those forms is sent directly to a third party.  Vance is not responsible for the information practices of such third parties, and you are encouraged to review their privacy policy before providing any information.

Information You Provide About Someone Else.  If you give us Personal Information about somebody else, such as a spouse, friend, or work colleague, we will assume that you have their permission to do so.  If you ask us send someone else a communication from a Web Site, such as sending an article to a friend, we use the information you provide (e.g., name, e-mail address, etc.) on a one-time basis to facilitate the communication and do not use it for any other marketing purpose unless we obtain consent from that person.

5.   NOTICE TO PARENTS

The Web Sites are general audience web sites, and we do not knowingly collect any Personal Information from children younger than the age of thirteen (13).  We will delete any Personal Information collected that we later determine to be from a user younger than the age of thirteen (13).

6.   CHANGING YOUR INFORMATION AND SUBSCRIPTIONS

Some of the Web Sites may provide functionality to allow you to correct or update Personal Information you have provided through certain portions of a registration form or otherwise.  In such case, you are responsible for maintaining the accuracy of the information you submit to us.  We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.  You may cancel or modify your subscriptions to e-mails you have elected to receive from a Web Site by following the instructions contained within the e-mail you receive from the Web Site.

7.   LINKS TO THIRD PARTY WEB SITES

The Web Sites may link to or contain links to third party web sites that Vance does not own or control.  Vance is not responsible for the privacy practices employed by any third party web site.  For example, if you "click" on a link from a Vance partner or advertisements on a Web Site, the "click" may take you off the Web Site onto a different web site.  These other web sites may send their own cookies to you, independently collect data or solicit Personal Information and may or may not have their own published privacy policies.  Vance encourages you to note when you leave our Web Sites and to read the privacy statements of all third party web sites before submitting any Personal Information to those web sites.

8.   THIRD PARTY AD SERVER NETWORKS

We may use third parties such as network advertisers to serve advertisements on the Web Sites and may use traffic measurement services to analyze traffic on the Web Sites. Network advertisers are third parties that display advertisements based on your visits to a Web Site and other websites you have visited.  Third-party ad serving enables us to target advertisements to you for products and services in which you might be interested.  The third party ad network providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own cookies on your computer and track certain behavioral information regarding users of your computer via a Device Identifier.  These third party cookies may be used, among other things, to: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you.  Note that any images (or any other parts of a web page) served by third parties in association with third party cookies may serve as web beacons, which enable third parties to carry out the activities described above.  Third party cookies and web beacons are governed by each third party's specific privacy policy.  While we may use a variety of companies to serve advertisements on the Web Site, you may wish to visit Network Advertising Initiative ("NAI") which provides information regarding this practice, and your choices regarding use of this information by these third parties, including the "opt-out" procedures of NAI members. 

9.   THIRD PARTY APPLICATIONS

Third party applications may be available via some of the Web Sites.  The owners of these applications ("Third Party Owners") may collect Personal Information from you and may have their own policies and practices.  Vance has no control over how Third Party Owners or their applications use your Personal Information.  These Third Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same.  Vance is not responsible for the policies or practices of Third Party Owners.  Be sure to review any available policies before submitting any Personal Information to a third party application or otherwise interacting with it. 

10. CONSENT TO TRANSFER INFORMATION TO THE UNITED STATES

The Web Sites are operated in the United States.  If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect will be transferred to and processed in the United States.  By using any of the Web Sites or providing us with any information, you consent to this transfer and processing of your information in the United States.

11. SECURITY

Vance takes commercially reasonable steps to help protect and secure Personal Information.  However, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure.  Please note that we can not ensure or warrant the security of any information we collect, and you use our Web Sites and provide us with your information at your own risk. 

12. EEOC/AFFIRMATIVE ACTION REPORTING

If you choose to apply for a job through a Web Site or take advantage of any job search services available on a Web Site, in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission ("EEOC"), the Office of Federal Contract Compliance Programs ("OFCCP") and similar state and local regulatory agencies, we may ask you to provide us with additional self-identifying Personal Information (such as veteran status, gender and ethnicity).  Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies for business-related purposes, including, but not limited to responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints. 

13. CHANGES TO THE PRIVACY POLICY

Vance reserves the right to change this Privacy Policy at any time without notice to you.  Any changes will be effective immediately upon the posting of the revised Privacy Policy.  However, Vance will not use your Personal Information in a manner materially different than what was stated at the time it was collected unless we receive your consent. 

14. CONTACT US; QUESTIONS

In you have any questions regarding this Privacy Policy, please contact us via e-mail via telephone at 847-634-2600 or via mail at:

Vance Publishing Corporation

400 Knightsbridge Parkway

Lincolnshire, IL 60069