Privacy at Newman’s Own Newman’s Own is committed to protecting the privacy of our web site visitors. We uphold the highest industry standards in online privacy and permission marketing. Security and Privacy Newman’s Own’s web site uses security measures to protect against the loss, misuse, and alteration of the information under our control. We store the information in a database in a secure environment at our data center. We will never share, sell, or rent individual personal information with anyone without your advance permission or unless ordered by a court of law. Information submitted to us is only available to employees managing this information for purposes of contacting you or sending you e-mails based on your requesting information Information Tracked At times we will use your IP address to help diagnose problems with our server and to administer our web site. We also may track browser types to help us understand our visitors’ needs related to our web site design. There is a section of our web site where input forms require your name and e-mail address. This form provides the ability to opt-in to receiving future emails of any sort from Newman’s Own. If you opt-in to receiving email communications from us, then we may send information to you about our products. You may review and change your information with us at any time by clicking on the “unsubscribe” link or similar found at the bottom of emails sent via our system. Web Beacons In order to determine a user’s ability to receive HTML email in addition to whether or not an email has been opened, Newman’s Own includes a “web beacon” in a majority of the HTML email messages we send. A web beacon (actually a small .gif image) is activated when an HTML email is opened via a request for the image on our servers. This capability helps Newman’s Own send email in a format users can read and enables Newman’s Own to track the aggregate number of emails opened. The web beacon does not collect any personally identifiable information. Users that do not want to receive email messages with web beacons can choose to receive their emails in text (non-HTML) format. We also have the capability to track when a URL has been clicked inside of an email message sent by our system. We use this functionality to track which links were clicked and in what quantity, as well as the aggregate number of links clicked. This click tracking functionality does not collect any personally identifiable information. Links to other Websites Newman’s Own is not responsible for the privacy practices or the content of any other web sites to which we link. Safe Harbor Data Privacy Notice Newman’s Own adheres to the Safe Harbor Principles published by the U.S. Department of Commerce (the “Safe Harbor Principles”) with respect to personal information (as defined below) it receives from the European Union. This notice outlines our general policy and practices for implementing the Safe Harbor Principles, including the type of information to which this notice applies, how we use personal information, and the choices individuals have regarding our use of, and their ability to correct, that personal information. If there is any conflict between the policies in this notice and the Safe Harbor Principles, the Safe Harbor Principles will govern. This notice applies to all personal information we handle, including on-line (except as noted below), off-line, and manually processed data. For purposes of this notice, “personal information” means data that: is transferred from the European Union to the United States; is recorded in any form; and is about, or pertains to, a specific individual who is identified in, or is identifiable from, the data. “Sensitive information” is a subcategory of personal information. Sensitive information is defined as personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or the sex life of the individual. Sensitive information also includes personal information received from a third party where the third party treats and identifies it as sensitive. Safe Harbor Principles Regarding Personal Information Notice and Choice We notify individuals about the personal information we collect from them, how we use it, and how to contact us with privacy concerns. We obtain personal information only as permitted by the Safe Harbor Principles or with the consent of the individual affected. Consent for personal information to be collected, used, and/or disclosed in certain ways may be required in order for an individual to obtain or use our services. To the extent permitted under the Safe Harbor, we reserve the right to process personal information in the course of providing professional services to our clients without the knowledge of individuals involved. Disclosures and Transfers We do not disclose personal information to third parties, except when one or more of the following conditions is true: We have the individual’s permission to make the disclosure; The disclosure is permitted by law or mandatory professional standards; The disclosure is reasonably related to the sale or other disposition of all or part of our business or assets; The personal information to be disclosed is publicly available; The party to whom the disclosure is made controls, is controlled by, or is under common control with Newman’s Own; The disclosure is reasonably necessary for the establishment or maintenance of legal claims; or The disclosure is to persons or entities for whom we are providing services, provided the disclosure is consistent with the purpose for which the personal information was obtained. We will comply with the Safe Harbor Principles with respect to disclosures of sensitive information, including, when applicable, obtaining the explicit consent of the individual prior to disclosing sensitive information to a third party or using sensitive information for purposes other than those for which it was originally collected or subsequently authorized by the individual. Transfers of information permitted under this notice, either to third parties or within Newman’s Own, include the transfer of data from one jurisdiction to another, such as transfers to and from the United States of America.