PRIVACY POLICY

Overview

Our site visitors’ privacy and trust are important to us. We provide this notice in order to make  sure that your expectations and our practices are aligned and that you are aware of your choices  with regard to our use and disclosure of the information you provide to this site. This Privacy  Policy describes the policies of Pantheon Media Group LLC (“PMG” or “we” ) regarding the  collection, use, disclosure and protection of the following types of information: Information obtained when you (“you” or “User”) visit the website www.graziamagazine.com  (each a “Site”, and collectively the “Sites”).

Information obtained through e-mail communications with you related to the Sites. This privacy  policy does not apply to information we collect by other means (including offline) or from other  sources. Your use of these Sites constitutes your acceptance of this Privacy Policy and your  consent to any action we take with respect to your information in compliance with this Privacy  Policy. We may change the terms of this Privacy Policy, so Users are encouraged to review this  page from time to time. Your continued use of these Sites following the posting of changes to the  Privacy Policy means that you accept the changes.

Information We Collect and How We Collect It

We require you to provide certain information about yourself if you register with these Sites or  request products and services. We also collect information when you participate in contests and  surveys, when you respond to requests for feedback, and when you submit postings to public  areas of these Sites (e.g., blogs, moderated discussions, and bulletin boards). The information we collect may include information from which you may be personally  identified (“Personally Identifiable Information”), such as name, postal address, telephone  number, fax number and e-mail address, and certain business information such as employer  name, occupation, job function, job title and buying information (e.g., preferences or history).  We also will collect credit card and related information when you request a product or service  (including, if applicable, registering for any of the Sites) for which there is a charge. These Sites  only collect Personally Identifiable Information with your knowledge.

When you visit these Sites, we may collect the IP address of your computer. We also use  automatic data collection technology to record other information that identifies your computer  and tracks your behavior on this Site. Methods used to collect this information may include  “cookies” and “clear GIFs” (also known as “pixel tags” or “beacons”). A cookie is a small  amount of data that is sent to your browser from a server and stored on your computer’s hard  drive. Most browsers allow Users to block the receipt of cookies, but doing so may compromise  your ability to use certain features of these Sites. A clear GIF is a small graphic image, typically  used in connection with cookies, that is placed on a website or in an email message. A clear GIF  can monitor certain user behavior, such as your usage of the website, whether you opened an  email message, or whether you clicked on a URL in an email message. We do not collect  Personally Identifiable Information in this way, but if you provide us with Personally Identifiable

Information, we may associate that information with the information that is collected  automatically.

Some of the materials included on these Sites, including advertising, may be served by third  parties. These third parties, in the course of serving such materials, may collect information  regarding your use of these Sites and how you respond to e-mail communications, using methods  that may include automatic data collection, and may use this information in order to present  advertisements or other content that may be of interest to you on these Sites and other websites.  Collection, use, disclosure, and security of information collected by third parties are subject to  the privacy policies of those third parties. If you would like more information about this practice  or to opt out of having this information used by certain third-party ad servers to provide targeted  ads, please visit http://www.networkadvertising.org/optout_nonppii.asp.

How We Use Your Information

We use Personally Identifiable Information collected on these Sites for the following purposes:

∙ To provide you with these Sites and other products and services.

∙ To respond to your inquiries and contact you about changes regarding these Sites. ∙ To provide you with e-mail, fax and other notices (such as expiration and renewal  notices) regarding your account and the products or services that you are receiving, and  for billing and collection purposes.

∙ For any other purpose disclosed at the time the information is collected or to which you  consent.

∙ As otherwise specifically described in this Privacy Policy.

∙ We also may use your information to better understand our Users and to improve our  Sites. For example, we may use this information to determine what portions of these Sites  are most popular and the demographics of our Users generally. Cookies and other User  information also enable us to customize your experiences on the Sites. We may use IP  addresses to help diagnose problems with our servers or to administer our Sites. We may  also use IP addresses to help identify a User during a particular session and to gather data  regarding use of our Sites.

∙ We may use the information you provide us to send you e-mail, fax and other  communications on behalf of PANTHEON MEDIA GROUP LLC and our affiliates.  These communications may include e-mail newsletters, as well as offers for other  PANTHEON MEDIA GROUP LLC services. All email newsletters will provide you  with an opportunity to opt out of receiving future issues of the newsletter. All  promotional offers will include an opportunity to opt out of receiving future promotions  from the brand whose product/service is being promoted.

∙ We also may use your information to send you e-mail and other communications on  behalf of third parties. Each of these communications will include instructions for opting  out of receiving future third party offers from us. You may also opt out of receiving third  party offers from our Sites at any time by sending an e-mail to contact@graziausa.com with the subject line “OPT OUT – THIRD PARTY.”

Our Disclosure of Your Information

We may disclose aggregated, anonymous statistics about many Users, and individual information  that is not Personally Identifiable Information without restriction as long as no individual is  identifiable by the information disclosed, and otherwise will not disclose your Personally  Identifiable Information except as follows:

∙ Name and/or business name and title (but not information by which you may be  contacted (i.e. name, postal address, telephone number, fax number and e-mail address)  in representative lists of our magazine circulation and/or website memberships, but not  for further use or dissemination by the recipient.

∙ To third parties engaged to provide services under contractual requirement to keep  Personally Identifiable Information confidential and use it only to perform the services. ∙ Portions of our Sites may be provided as “Premium” or “Sponsored” content. Premium or  Sponsored content is made available to Users on the condition that we may share certain  of the User’s registration information with the Premium or Sponsored content’s sponsors  and advertisers and/or their service providers. We will always disclose when you are  registering or being provided with Premium or Sponsored content.

∙ To other third parties (and/or to their service providers on their behalf) to market their  products or services under contractual requirement to keep Personally Identifiable  Information confidential and use it only to market and provide their products or services.  You may opt out of such disclosures by sending an e-mail to contact@graziausa.com with the subject line: “DO NOT DISCLOSE.”

To any successor pursuant to an asset sale, merger, consolidation, restructuring, reorganization,  liquidation, or other similar transaction involving PANTHEON MEDIA GROUP LLC or any of  our Sites.

When we believe such disclosure is required by law, regulation, or securities exchange  requirement, or for the protection of persons or property.

When disclosure is necessary to accomplish the purpose for which you provide it. To other PANTHEON MEDIA GROUP LLC member companies for any uses consistent with  those disclosed in this Privacy Policy.

Security

We use reasonable safeguards to protect Personally Identifiable Information we collect on our  Sites from unauthorized access, use, modification, or disclosure. However, due to the design of  the Internet and other factors outside of our control, we cannot guarantee that communications  between you and our servers will be free from unauthorized access by third parties.

Right to Access and Change Information

You may view and update information that you previously submitted to our Sites by visiting the  newsletter or website registration page for the Site, or which you submitted to request a print  publication, by sending an e-mail to contact@graziausa.com. However, a request to change

information may not be accommodated if the request would conflict with legal requirements or  result in incorrect information. Requests to view or change personal information may take a few  days to process.

Links

Our Sites contain content, services, advertising and other materials that link to websites operated  by third parties. We have no control over those other sites, and this Privacy Policy does not apply  to them.

We encourage you to refer to the privacy policies, if any, of those sites.

This Site is operated by:

Pantheon Media Group LLC

28 Park Ave South 

#60778 

New York 

NY 10003-1502

contact@graziausa.com

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