Privacy Statement

Victory Journal LLC (“Victory,” “we,” “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this policy. This privacy statement, which is effective as of February 24, 2015, describes the types of information we may collect from you or that you may disclose when you visit our Site, located at www.victoryjournal.com (the “Site”) and our practices for collecting, using, maintaining, protecting and disclosing that information.

THIS PRIVACY STATEMENT APPLIES TO INFORMATION WE COLLECT:

On the Site;

In e-mail, text, electronic newsletters in which you enroll, and other electronic messages between you and the Site;

Through mobile and desktop applications you download from this Site, which provide dedicated non-browser-based interaction between you and this Site;

When you interact with our advertising and applications on third-party Sites and services, if those applications or advertising include links to this policy;

Through offline means such as telephone, traditional mail, or in person contact with us;

Through any other online or offline means in connection with Victory or products and services provided by Victory; and

Through any other online or offline means in connection with Victory’s affiliates and subsidiaries, or products and services provided by such affiliates and subsidiaries.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use the Site. By accessing or using the Site, you agree to this privacy statement. This privacy statement may change from time to time, and your continued use of this Site after we make changes to the privacy statement is deemed to be acceptance of those changes, so we encourage you to check our privacy statement periodically for updates.

CHILDREN UNDER THE AGE OF 13

The Site is not intended for children under 13 years of age. No one under age 13 may disclose any personal information to or on the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not disclose any information on this Site or on or through any of its features, register on the Site, make any purchases through the Site, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any user name. If we learn we have collected or received personal information from a child under 13 without parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@victoryjournal.com.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from and about users of the Site, including information:

By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other information that is defined as personal or personally identifiable information under applicable laws (“personal information”);

Any other identifier by which you may be contacted online or offline;

That is about you but individually does not identify you, for example, browsing trends and other consumer data; and

About your internet connection, the equipment you use to access our Site and usage details.

We collect this information:

Directly from you when you provide it to us;

Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses and information collected through cookies and other tracking technologies; and

From third parties, for example, our affiliates, subsidiaries, and other associated business partners and third parties with which we conduct business (collectively, our “Business Partners”).

INFORMATION YOU PROVIDE TO US AND INFORMATION WE COLLECT.

The information we collect on or through our Site may include:

Information that you provide by filling in forms on the Site. This includes information provided at the time you register to use the Site, subscribe to our services, post material on or through the Site, or request further services. We may also ask you for information when you enter a contest or promotion sponsored by us or our affiliates, subsidiaries and associated business partners and third parties, or when you report a problem on the Site;

Records and copies of your correspondence, including e-mail addresses, if you contact us;

Your responses to surveys that we might ask you to complete for research purposes;

Details of transactions you carry out through the Site and of the fulfillment of your orders. You may be required to provide financial and other personal information before placing an order through the Site;

Your search queries on the Site; and

Your IP Address, browser type and version, operating system and platform, average time spent on our Site, pages viewed, information searched for, access times, and other relevant information about your online experience.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site, or transmitted to other users of the Site or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although, we may limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we do not guarantee that your User Contributions will not be viewed by unauthorized persons.

THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use the Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different Sites and other online services. They may use this information to provide you with interest-based advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

FIRST-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

We have partnered with Google Inc. (“Google”) to enable the Google Analytics Advertiser Feature, “Google Analytics Demographics and Interest Reporting” (“Google Analytics”) to collect information about the use of the Site. Google Analytics is a web analysis service provided by Google that employs only first-party cookies (cookies that are linked to a specific website domain) to define user sessions on the Site. Google Analytics enables us to collect certain data about traffic to the Site via Google advertising cookies that aggregate anonymous data related to a user’s browsing behavior, how often users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. Google Analytics collects only the IP address assigned to you on the date you visit the Site, rather than your name or other identifying information. Google utilizes the data it collects to track and examine the use of our Site on our behalf, and also to prepare reports on its activities, and share them with other internal Google services. The data collected via Google Analytics cannot be altered or retrieved by services from other domains. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Site, the cookie cannot be used or accessed by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use (http://www.google.com/analytics/terms/us.html) and the Google Privacy Policy (http://www.google.com/policies/privacy/). You can find more information about how Google uses, collects and processes data generated through Google Analytics here: https://www.google.com/policies/privacy/partners/

We use the information we get from Google Analytics only to improve the Site and do not use Google Analytics to track, collect or upload any data that personally identifies an individual (such as a name, email address or billing information), or other data which can be reasonably linked to such information by Google, or combine the information collected through Google Analytics with personally identifiable information.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

To present the Site and its contents to you;

To provide you with information, products or services that you request from us or our affiliates;

To fulfill any other purpose for which you provide it;

To provide you with notices about your account, subscription (including expiration and renewal notices) and offers;

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

To notify you about changes to the Site or any products or services we offer or provide though it;

To allow you to participate in interactive features on the Site;

To offer you products, services and information and to share with our Business Partners, which so our Business Partners can offer you products, services or information that may interest you, either in conjunction with Victory or by themselves;

In any other way we may describe when you provide the information; and

For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual user with specificity, without restriction. We may disclose personal information that we collect or you provide as described in this privacy statement:
To our Business Partners;

To contractors, service providers and other third parties we use to support our business;

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or other similar proceeding, in which personal information held by us about our Site users is among the assets transferred;

To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them;

To fulfill the purpose for which you provide it (for example, if you give us an e-mail address to use the “e-mail a friend” feature on our Site, we will transmit the contents of that e-mail and your e-mail address to the recipients;

For any other purpose disclosed by us when you provide the information;

With your consent;

To comply with any court order, law or legal process, including to respond to any government or regulatory request;

To enforce or apply our Terms and Conditions, Terms of Sale and other agreements, including for billing and collection purposes; and

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Victory, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, including those generated by Google Analytics, or to alert you when cookies are being sent. To learn how you can manage your cookie settings, visit the Flash player settings page on Adobe's Site. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. You can prevent your data from being used by Google Analytics without affecting how you visit the Site by installing the Google Analytics opt-out browser add-on found here: https://tools.google.com/dlpage/gaoptout. In addition, you can click on the following link for additional information that can help you control the ads by Google that you see on our Site: https://www.google.com/safetycenter/tools/#manage-your-ads-preferences.Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by emailing us at privacy@victoryjournal.com and by specifically telling us to not share your information

Promotional Offers from Victory. If you do not wish to have your e-mail address/contact information used by us to promote our own or our third parties’ products or services, including of Business Partners’, you can opt-out by sending us an email specifically stating your request to privacy@victoryjournal.com. If we have sent you a promotional e-mail, you may send a request to the above email or follow the instructions in that email to be omitted from future e-mail distributions.

Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by you can opt-out by sending us an email specifically stating your request to privacy@victoryjournal.com.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) which can be located here: http://www.networkadvertising.org/

ACCESSING AND CORRECTING YOUR INFORMATION

You can review and change your personal information by logging into the Site and visiting your account profile page. You may also send us an e-mail specifically stating your request to privacy@victoryjournal.com. to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including User Contributions, is governed by our Terms of Use.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you, or where you have chosen, a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We advise you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

CALIFORNIA PRIVACY RIGHTS

Notice to California Customers California's “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. As noted herein, if you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes offline please contact us at our contact information provided below.

CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices, contact us:

by e-email at privacy@victoryjournal.com,
by mail at 85 Metropolitan Avenue, Brooklyn, New York 11249, Attn: Privacy
or by phone at 212-388-0332.