THE RDN Privacy Notice

Effective Date: January 1, 2021

1. INTRODUCTION

Stepite, LLC, and its subsidiaries ("Retail Daily News" also defined as “RDN”) want you to be familiar with how we collect, use and disclose information from and about you because we respect your concerns about privacy, and we want to maintain your trust.

This Privacy Notice applies to information we collect from all sources, including in connection with our websites, mobile sites, applications ("apps"), widgets, conferences, events, and electronic newsletters or communications (collectively the "RDN Services") that link to this Privacy Notice. If there is a conflict between this Notice and a RDN Services corporate subscription agreement, the RDN Services corporate subscription agreement will take precedence.

This Notice describes the types of Personal Data we collect, how we use it, and with whom we share it. It also describes generally RDN's practices for handling Other Information (e.g., interests, demographics and services usage) collected through our RDN Services or from a third party to the extent such information is associated with a particular device, user or user account. We also describe the measures we take to protect the information, your options for choice and access, and how you can contact us about privacy practices. As described more fully below, we share information with our subsidiaries, and affiliated companies ("RDN Affiliates"), for the purposes described in this Privacy Notice. A list of RDN subsidiaries and Affiliates is available by contacting us at ads@retaildailynews.com. By using the RDN Services, you acknowledge you have read and accept this Privacy Notice.Your decision to use the RDN Services and provide your Personal Data is voluntary. We indicate on our online, mobile, and other registration forms what types of Personal Data are requested. 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 Notice, for more information), but that may limit the services RDN is able to provide to you.

The RDN Services are a network of general audience sites, and are not targeted to, and do not knowingly collect Personal Data from, minors under 16 years of age. We request that these individuals do not provide Personal Data through the RDN Services.

2. WHAT WE COLLECT

RDN and our service providers collect Personal Data to offer services you have requested or that we have a legitimate interest to believe are of interest to our customers, to manage the relationships we have with our customers and partners, and to perform activities based on your consent. RDN and our service providers may collect the following information from and about you:

2.1 Personal Data

"Personal Data" for purposes of this Privacy Notice is the information that identifies you as an individual or relates to an identifiable person.

2.1.1 Personal Data You Submit

We collect Personal Data when you submit it to us, such as when you register for or subscribe to certain products or services; create a profile; participate in a sweepstakes, contest or game; take a survey; visit our RDN Services; use an interactive feature (such as chat, chat bot or article sharing options); scan or use our QR codes; participate in a community forum; register for an event or conference; or contact customer service. The Personal Data you submit may include your name, postal address (including billing and shipping addresses), credit or debit card number, telephone number, mobile number, email address, gender, username, or profile picture.

2.1.2 Personal Data We Receive From Third Parties

To the extent permitted by applicable law, we may receive Personal Data about you from third parties, such as social media services, commercially available sources, RDN Affiliates, business partners, and, if applicable to you, the third party provider of your subscription. The Personal Data we receive from third parties may include your name, contact information, information about your transactions, purchase history, or relationships with various product and service providers, and your use of certain applications. For example, if you access a RDN Service through a social media service or connect a RDN Service to a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content the social media service will share with us, such as your profile picture, or email address. The information we obtain depends on your privacy settings on the applicable social media service. When you access the RDN Services through social media services or when you connect a RDN Service to social media services, you are authorizing RDN to collect, store, and use such information and content in accordance with this Privacy Notice.

2.2 Other Information

"Other Information" is any information that is not intended to reveal your specific identity to us, such as browser information, usage data, information collected through cookies and other technologies, demographic information, geolocation data obtained with your consent where required by applicable law, and aggregated information.

2.2.1 Other Information You Submit

We collect Other Information when you submit it to us. This may include your password, birthday, education or graduation year, occupation, financial information (such as your income, investments, portfolio transactions and value, and other information), live event accommodations, and interests.

2.2.2 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.

2.2.3 Other Information Collected Automatically

Our services use cookies and other tracking technologies to function effectively and deliver certain features. For more information about how we use cookies and tracking technologies, please refer to our Cookie Notice.

The RDN Services may also be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality, games or applications developed and maintained by third parties, using iframes, tools, or plug-ins (“Linked Services”). These third party Linked Services may use automated means to collect information about you and your use of these features. Some of these third party sites may be co-branded with a RDN logo, even though they are not operated or maintained by us.

RDN is not responsible for the privacy practices of such third parties, and once you leave the RDN Services or click an advertisement, or sign up for a special offer, you should check the applicable third party privacy notice.

3. HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION

We may use the Personal Data we collect from and about you for the purposes set forth below. We may use and disclose Other Information for any purpose, except if it is considered Personal Data under applicable law. If we combine Other Information with your Personal Data, we treat the combined information as Personal Data.

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 RDN products, services and websites. In addition, we may supplement the Personal Data 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 RDN Affiliates or business partners.

Through third party analytics providers, ad networks, and advertisers, we can track your online activities over time and across third party websites, apps and devices, by obtaining information through automated means.

This information, along with information we gather when you log in, can be used to understand use across sites and devices to help improve our products, remember your preferences, provide content recommendations, and show you advertisements on the RDN Services or other third party websites and apps that may be tailored to your individual interests. For more information, including how to manage cookies, please refer to our Cookie Notice.

3.1 To Provide, Measure And Improve Our Products And 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 create and manage your accounts, to send you information about your relationship or transactions with us, to measure and improve services and features, to allow you to engage with us (e.g., to comment on content and participate in online games, contests, promotions, special events, rewards programs, surveys or market research), to use collaboration tools to share content and collaborate with other users, to conduct research for potential articles if you choose to respond to a journalism survey, to provide you with customer support, including online chat or chat bot, and to respond to inquiries. If you choose to use the collaboration tools, some of your Personal Data 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 RDN websites with the same user ID.

3.2 To Deliver Relevant Content And Recommendations

To make your experience more interesting and personalized, we may use any of the Personal Data and Other Information we collect to assist us in delivering content on any of our RDN Services. For example, if you use retaildailynews.com and stepite.com, we may use your retaildailynews.com reading history to personalize the content delivered to you on stepite.com.

3.3 To Deliver Advertising And Interest-Based Advertising

The RDN Services 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 ads about products and services tailored to your individual interests to you when you use the RDN Services or another service provided by RDN, RDN Affiliates, or unaffiliated third parties. (See What We Collect, above, for details on the types of information we may use.) We may work with third party online advertising companies, advertisers and ad networks who help deliver these ads to you. These third parties may collect and use information about your activities on our RDN Services and on other websites, and Other Information about you which may include offline purchases, to limit the online ads you encounter to those we believe are consistent with your interests.

To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising. To learn how to opt out of online interest-based advertising, please follow the instructions in the Your Rights and Choices section below.

If you provide your mobile phone number to us, we may ask for your consent to receive text message alerts from us containing product, event, or promotional information in a text or SMS message (“Text Messages”). Your consent to receive Text Messages is not required to purchase goods or services from us.

3.4 To Allow Social Sharing Functionality

If you log in with or connect a social media service account with a RDN Service, we may use Personal Data and Other Information to facilitate your sharing of information between the RDN Services and your social media service.

3.5 To Contact You

RDN and RDN Affiliates may periodically send promotional materials, with your permission where required, surveys, market research, contest or promotional awards, 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 Data and Other Information we collect to assist us in sending you these materials. We may also use your information (including a telephone or mobile number you may have provided for this purpose) to contact you, including to respond to your comments, inquiries or requests. If you want to stop receiving these materials, please follow the instructions in the Your Rights and Choices section below .

3.6 To Protect The Rights Of RDN And Others

RDN may use your Personal Data as we believe to be necessary or appropriate in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of RDN, our RDN Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.

4. HOW WE SHARE YOUR PERSONAL DATA AND OTHER INFORMATION

4.1 Our Disclosure of Personal Data and Other Information

Stepite, LLC and its subsidiaries may share your Personal Data with one another, as well as with RDN Affiliates for the purposes described in this Privacy Notice, including for each company's marketing purposes if you have consented to such use. Users who visit RDN Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Notice. RDN is the party responsible for the management of the jointly-used Personal Data.

In addition, we may share your Personal Data with non-affiliated third parties when sharing is permitted by you or authorized by this Privacy Notice, including:

4.1.1 To Manage Corporate, Third Party, and School Subscriptions

If your subscription is provided in whole or in part by your employer, school or other third party, we may share with them information about your access to and use of your subscription. If you have a subscription associated with a professor or school, we may also contact your professor or school to confirm your subscription. When providing this information, we may reveal limited amounts of your Personal Data such as your name or email address.

4.1.2 To Allow Third-Party Service Providers To Assist Us In Providing and Managing Our Services

We may make your Personal Data available to third party service providers, such as contractors, agents or sponsors, or RDN Affiliates, 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. These third party service providers are required to protect Personal Data entrusted to them and not use it for any other purpose than the specific service they are providing on our behalf.

4.1.3 To Provide Co-Branded Services And Features

We may offer co-branded services or features, such as conferences, events, contests, sweepstakes or other promotions together with a third party ("Co-Branded Services"). These Co-Branded Services may be hosted by the RDN Services 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 notice.

4.1.4 To Permit Unaffiliated Third Parties To Send Promotional Materials To U.S. Print Subscribers

If you subscribe to the U.S. edition of Retail Daily News or RDN’s print publications, we may share your print mailing address with unaffiliated third party 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 Your Rights and Choices.

4.1.5 To Allow Social Sharing Functionality

If you log in with or connect a social media service account with a RDN Service, you are authorizing us to share information we collect from and about you with the social media service provider and other RDN Services, and you understand that the social media service's use of the shared information will be governed by the social media service's privacy notice. If you do not want your Personal Data shared in this way, please do not connect your social media service account with your RDN Services account, and do not participate in social sharing on the RDN Services.

4.1.6 To Protect The Rights Of RDN And Others

There may be instances when RDN may disclose your Personal Data, including situations where we have a good faith belief that such disclosure is necessary in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of RDN, our RDN Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.

4.1.7 To Complete A Merger, Sale Of Assets, Or Bankruptcy

If RDN sells all or part of its business or assets, or is otherwise involved in a merger, reorganization, dissolution, liquidation, or transfer of all or part of its business, as part of that transaction RDN may transfer your information to the party or parties and their advisors involved in the transaction.

4.2 Information Made Public Through Use of Our Services and User Privacy Settings

Certain features on the RDN Services 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 choose to submit, including your name, user name, location, email address, profile information, picture or image, 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 RDN Services. We are not responsible for any information you choose to submit and make public through these interactive features.

5. HOW WE PROTECT AND RETAIN PERSONAL DATA

RDN uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Data in its possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data. 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 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.

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

6. YOUR RIGHTS AND CHOICES

6.1 Your Choices Regarding Our Use and Disclosure of Your Personal Data

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

6.1.1 To Opt Out Of Direct Marketing From RDN And RDN Affiliates

You may opt out of receiving electronic communications from us (including surveys, notifications, or promotions from us on behalf of third parties), or our sharing of your Personal Data with RDN 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 can opt out of direct marketing from RDN Affiliates by using the unsubscribe links they provide or following the steps in their applicable policies.

Please note that there are certain service notifications that you may not opt out of, such as renewal notices and notifications of changes to RDN 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.

6.1.2 To Opt Out Of Direct Marketing From Unaffiliated Third Parties

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 WSJ U.S. edition or Barron’s print subscriber) by contacting Customer Service.

6.1.3 To Opt Out Of Online Interest-Based Or Text Advertising

You may also opt out of online interest-based advertising by taking the steps detailed in our Cookie Notice.

If you consented to receiving promotions or advertising via Text Message, you can unsubscribe from receiving Text Messages at any time by replying “STOP” to one of our Text Messages.

6.1.4 To Change Mobile App Privacy Settings

You may change the privacy settings for RDN apps by accessing and updating privacy settings and permissions within the mobile app or on your mobile device.

6.2 How To Access, Correct or Update Your Personal Data

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 Data 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.

If you are in the European Economic Area or Switzerland (collectively, “EEA”), you can also object to or restrict the processing of your Personal Data, or exercise your right to data portability. If you are in Nevada, you can also exercise your “Do Not Sell” right to opt out of interest-based advertising here or here. More information about opting out of Advertising Cookies is provided in our Cookie Notice. For California residents, please see additional detail below in the California Privacy Rights section.

Here are links to pages where subscribers and registered users may update their personal profile information, marketing and newsletter preferences, or find local contact information for RDN Services:

RDN Contact Page
Retail Daily News Emails and Alerts

Where you have provided your consent for our use of your Personal Data, you have the right to withdraw your consent and we will apply your preferences going forward.

For your protection, we may only implement requests with respect to the Personal Data 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 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 Data provided until after the completion of such purchase or promotion).

6.3 California Privacy Rights

6.3.1 California Shine the Light

Subject to certain limitations, California Law permits California residents to request certain information regarding our disclosure of Personal Data during the past 12 months to third parties for their own direct marketing purposes. To make such a request, California residents can write to us at privacypolicy@retaildailynews.com, Attn: Privacy Team, Re: CA Shine the Light, and include your name and the address to which you would like us to respond.

6.3.2 California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (“CCPA”) requires notice about certain issues, and provides specific rights to California residents, which are detailed below. Where indicated, certain terms in this section 6.3.2 have the meaning given to them in the CCPA.

6.3.2.1 CCPA Privacy Notice

The following chart lists the categories of Personal Data and Other Information (together, Personal Information as defined in the CCPA) we, in the past 12 months, may have collected from and about individuals who use our Services, sources of that information, purposes for which we may have used the information, and third parties with whom it may have been shared.

In the chart we reference relevant sections of our Privacy Notice (e.g., 3.1) and Cookie Notice (e.g., CN 5.5). For more detail about how we collect, use and share Personal Data and Other Information, please see our full Privacy Notice and Cookie Notice.

Categories of Personal Data and Other Information	Categories of Sources	Categories of Purposes of Use	Categories of Third Parties To Whom It May Be Disclosed – CCPA Business or Commercial Purpose	Categories of Third Parties To Whom It May Be Disclosed – CCPA Sale
Identifiers You supply such as your name, postal address (including billing and shipping addresses), credit or debit card number, telephone number, mobile number, email address, gender, username, profile information, profile picture or image, status, comments, email address, password, birthday, financial information (such as your income, investments, portfolio transactions and value, and other information), and interests. We obtain from third parties such as contact information, social media account number.	2.1.1 Personal Data You Submit 2.2.1 Personal Data We Receive From Third Parties 2.2.1 Other Information You Submit 2.2.2 Other Information We Receive From Third Parties	3.1 Provide, Measure and Improve our Products and Services3.2 Deliver Relevant Content and Recommendations3.3 Deliver Advertising and Interest-Based Advertising 3.4 Allow Social Sharing Functionality 3.5 Contact You 3.6 Protect the Rights of RDN & Others	4.1 RDN Affiliates 4.1.1 Third parties that manage your subscription 4.1.2 Third party service providers 4.1.3 Third party partners for co-branded services 4.1.5 Third parties you direct us to engage with, such as social networks or payment services 4.1.6 Authorities, regulators or government entities 4.1.7 Merger or acquisition entity	3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising* 4.1.4 Third Parties for their Direct Marketing Purposes**
Device Information/Identifiers Collected automatically such as browser information, usage data, and information collected through cookies and other technologies.	2.2.3 Other Information Collected Automatically	3.1 Provide, Measure and Improve our Products and Services 3.2 Deliver Relevant Content and Recommendations 3.3 Deliver Advertising and Interest-Based Advertising 3.6 Protect the Rights of RDN & Others	4.1 RDN Affiliates 4.1.2 Third party service providers 4.1.6 Authorities, regulators or government entities 4.1.7 Merger or acquisition entity	3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising*
Legally Protected or Medical Information You provide to us including gender, live event accommodations, or political or religious beliefs you may express or make public using one of our collaboration tools.	2.1.1 Personal Data You Submit 2.2.1 Other Information You Submit	3.1 Provide, Measure and Improve our Products and Services 3.6 Protect the Rights of RDN & Others	4.1 RDN Affiliates 4.1.2 Third party service providers 4.1.6 Authorities, regulators or government entities 4.1.7 Merger or acquisition entity
Commercial Information We receive from third parties such as information about your transactions, purchase history, or relationships with various product and service providers, and your use of certain applications.	2.1.1 Personal Data You Submit 2.1.2 Personal Data We Receive From Third Parties	3.1 Provide, Measure and Improve our Products and Services 3.2 Deliver Relevant Content and Recommendations 3.3 Deliver Advertising and Interest-Based Advertising 3.6 Protect the Rights of RDN & Others	4.1 RDN Affiliates 4.1.1 Third parties that manage your subscription 4.1.2 Third party service providers 4.1.3 Third party partners for co-branded services 4.1.6 Authorities, regulators or government entities 4.1.7 Merger or acquisition entity	3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising*
Biometric Information You provide such as a profile picture or image.	2.1.1 Personal Data You Submit	3.1 Provide, Measure and Improve our Products and Services3.6 Protect the Rights of RDN & Others	4.1.2 Third party service providers 4.1.6 Authorities, regulators or government entities 4.1.7 Merger or acquisition entity
Online/Internet Activity Information and Geolocation Data Information we obtain through the use of Cookies may include information about your computer, device, and browser, such as your IP address, browser type, operating system and device characteristics, language preferences, mobile device or advertising ID, referring URLs, and actions taken by you on the RDN Services such as what content you visited, whether you have used the RDN Services before, actions taken on the RDN Services, dates and times you access the RDN Services or visit specific pages, country information, email and advertising views and click-throughs, frequent article searches on the RDN Services, and other software or hardware information. If you access the RDN Services from a mobile or other device, we may collect information for that device such as a unique device identifier ("UDID"), mobile phone number, and details about your mobile carrier. Information third parties obtain on our behalf such as data about your visits to websites and use of apps that serve our advertisements, such as the pages, articles or ads you view and the actions you take on those websites or apps.	2.2.3 Other Information Collected Automatically	3.1 Provide, Measure and Improve our Products and Services 3.2 Deliver Relevant Content and Recommendations 3.3 Deliver Advertising and Interest-Based Advertising 3.5 Contact You 3.6 Protect the Rights of RDN & Others	4.1 RDN Affiliates 4.1.1 Third parties that manage your subscription 4.1.2 Third party service providers 4.1.3 Third party partners for co-branded services 4.1.6 Authorities, regulators or government entities 4.1.7 Merger or acquisition entity	3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising*
Professional Information You submit such as occupation.	2.2.1 Other Information You Submit	3.1 Provide, Measure and Improve our Products and Services 3.2 Deliver Relevant Content and Recommendations 3.3 Deliver Advertising and Interest-Based Advertising 3.5 Contact You 3.6 Protect the Rights of RDN & Others	4.1 RDN Affiliates 4.1.1 Third parties that manage your subscription 4.1.2 Third party service providers 4.1.3 Third party partners for co-branded services 4.1.6 Authorities, regulators or government entities 4.1.7 Merger or acquisition entity	3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising*
Education Information You submit including education or graduation year.	2.2.1 Other Information You Submit	3.1 Provide, Measure and Improve our Products and Services 3.2 Deliver Relevant Content and Recommendations 3.3 Deliver Advertising and Interest-Based Advertising 3.5 Contact You 3.6 Protect the Rights of RDN & Others	4.1 RDN Affiliates 4.1.1 Third parties that manage your subscription 4.1.2 Third party service providers 4.1.3 Third party partners for co-branded services 4.1.6 Authorities, regulators or government entities 4.1.7 Merger or acquisition entity	3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising*
Inferences Information We receive from third parties such as demographic data, information about your interests, marketing segment information, and information about your activities on other websites. Advertising Cookies remember what you have looked at or purchased on the Dow Jones Services and other sites, and may be combined with other information acquired from third parties such as demographics, offline purchases, and other marketing segment information, and we may share this information with other organizations, such as advertisers, in accordance with applicable law.	2.2.2 Other Information We Receive From Third Parties 2.2.3 Other Information Collected Automatically	3.1 Provide, Measure and Improve our Products and Services 3.2 Deliver Relevant Content and Recommendations 3.3 Deliver Advertising and Interest-Based Advertising 3.5 Contact You 3.6 Protect the Rights of RDN & Others	4.1 RDN Affiliates 4.1.2 Third party service providers 4.1.6 Authorities, regulators or government entities 4.1.7 Merger or acquisition entity	3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising*

Categories of Personal Data and Other Information

Categories of Sources

Categories of Purposes of Use

Categories of Third Parties To Whom It May Be Disclosed – CCPA Business or Commercial Purpose

Categories of Third Parties To Whom It May Be Disclosed – CCPA Sale

Identifiers

You supply such as your name, postal address (including billing and shipping

addresses), credit or debit card number, telephone number, mobile number,

email address, gender, username, profile information, profile picture or image, status, comments, email address, password, birthday, financial

information (such as your income, investments, portfolio transactions and

value, and other information), and interests. We obtain from third parties such as contact information, social media

account number.

2.1.1

Personal Data You Submit

2.2.1 Personal Data We Receive From Third Parties

2.2.1 Other Information You Submit

2.2.2 Other Information We Receive From Third Parties

3.1

Provide, Measure and Improve our Products and Services3.2 Deliver Relevant Content and Recommendations3.3 Deliver Advertising and Interest-Based Advertising

3.4 Allow Social Sharing Functionality

3.5 Contact You

3.6 Protect the Rights of RDN & Others

4.1

RDN Affiliates

4.1.1 Third parties that manage your subscription

4.1.2 Third party service providers

4.1.3 Third party partners for co-branded services

4.1.5 Third parties you direct us to engage with, such as social networks or

payment services

4.1.6 Authorities, regulators or government entities

4.1.7 Merger or acquisition entity

3, CN 4, and CN 5.5 Third parties who measure or deliver

Interest-based Advertising*

4.1.4 Third Parties for their Direct Marketing Purposes**

Device Information/Identifiers

Collected automatically such as browser information, usage data, and

information collected through cookies and other technologies.

2.2.3 Other Information Collected Automatically

3.1

Provide, Measure and Improve our Products and Services

3.2 Deliver Relevant Content and Recommendations

3.3 Deliver Advertising and Interest-Based Advertising

3.6 Protect the Rights of RDN & Others

4.1

RDN Affiliates

4.1.2 Third party service providers

4.1.6 Authorities, regulators or government entities

4.1.7 Merger or acquisition entity

3, CN 4, and CN 5.5 Third parties who measure or deliver

Interest-based Advertising*

Legally

Protected or Medical Information

You provide to us including gender, live event accommodations, or political

or religious beliefs you may express or make public using one of our

collaboration tools.

2.1.1

Personal Data You Submit

2.2.1 Other Information You Submit

3.1

Provide, Measure and Improve our Products and Services

3.6 Protect the Rights of RDN & Others

4.1

RDN Affiliates

4.1.2 Third party service providers

4.1.6 Authorities, regulators or government entities

4.1.7 Merger or acquisition entity

Commercial

Information

receive from third parties such as information about your transactions,

purchase history, or relationships with various product and service

providers, and your use of certain applications.

2.1.1 Personal Data You Submit

2.1.2 Personal Data We Receive From Third

Parties

3.1

Provide, Measure and Improve our Products and Services

3.2 Deliver Relevant Content and Recommendations

3.3 Deliver Advertising and Interest-Based Advertising

3.6 Protect the Rights of RDN & Others

4.1

RDN Affiliates

4.1.1 Third parties that manage your subscription

4.1.2 Third party service providers

4.1.3 Third party partners for co-branded services

4.1.6 Authorities, regulators or government entities

4.1.7 Merger or acquisition entity

3, CN 4, and CN 5.5 Third parties who measure or deliver

Interest-based Advertising*

Biometric

Information

You provide such as a profile picture or image.

2.1.1 Personal Data You Submit

3.1

Provide, Measure and Improve our Products and Services3.6 Protect the Rights of RDN & Others

4.1.2

Third party service providers

4.1.6 Authorities, regulators or government entities

4.1.7 Merger or acquisition entity

Online/Internet

Activity Information and Geolocation Data

Information we obtain through the use of Cookies may include information

about your computer, device, and browser, such as your IP address, browser

type, operating system and device characteristics, language preferences,

mobile device or advertising ID, referring URLs, and actions taken by you on

the RDN Services such as what content you visited, whether you have

used the RDN Services before, actions taken on the RDN Services,

dates and times you access the RDN Services or visit specific pages,

country information, email and advertising views and click-throughs, frequent

article searches on the RDN Services, and other software or hardware

information. If you access the RDN Services from a mobile or other

device, we may collect information for that device such as a unique device

identifier ("UDID"), mobile phone number, and details about your

mobile carrier. Information third parties obtain on our behalf such as data about your visits

to websites and use of apps that serve our advertisements, such as the pages,

articles or ads you view and the actions you take on those websites or apps.

2.2.3 Other Information Collected Automatically

3.1

Provide, Measure and Improve our Products and Services

3.2 Deliver Relevant Content and Recommendations

3.3 Deliver Advertising and Interest-Based Advertising

3.5 Contact You

3.6 Protect the Rights of RDN & Others

4.1

RDN Affiliates

4.1.1 Third parties that manage your subscription

4.1.2 Third party service providers

4.1.3 Third party partners for co-branded services

4.1.6 Authorities, regulators or government entities

4.1.7 Merger or acquisition entity

3, CN 4, and CN 5.5 Third parties who measure or deliver

Interest-based Advertising*

Professional

Information

You submit such as occupation.

2.2.1 Other Information You Submit

3.1

Provide, Measure and Improve our Products and Services

3.2 Deliver Relevant Content and Recommendations

3.3 Deliver Advertising and Interest-Based Advertising

3.5 Contact You

3.6 Protect the Rights of RDN & Others

4.1

RDN Affiliates

4.1.1 Third parties that manage your subscription

4.1.2 Third party service providers

4.1.3 Third party partners for co-branded services

4.1.6 Authorities, regulators or government entities

4.1.7 Merger or acquisition entity

3, CN 4, and CN 5.5 Third parties who measure or deliver

Interest-based Advertising*

Education

Information

You submit including education or graduation year.

2.2.1 Other Information You Submit

3.1

Provide, Measure and Improve our Products and Services

3.2 Deliver Relevant Content and Recommendations

3.3 Deliver Advertising and Interest-Based Advertising

3.5 Contact You

3.6 Protect the Rights of RDN & Others

4.1

RDN Affiliates

4.1.1 Third parties that manage your subscription

4.1.2 Third party service providers

4.1.3 Third party partners for co-branded services

4.1.6 Authorities, regulators or government entities

4.1.7 Merger or acquisition entity

3, CN 4, and CN 5.5 Third parties who measure or deliver

Interest-based Advertising*

Inferences

Information

We receive from third parties such as demographic data, information about

your interests, marketing segment information, and information about your

activities on other websites. Advertising Cookies remember what you have looked at or purchased on the Dow

Jones Services and other sites, and may be combined with other information

acquired from third parties such as demographics, offline purchases, and

other marketing segment information, and we may share this information with

other organizations, such as advertisers, in accordance with applicable law.

2.2.2

Other Information We Receive From Third Parties

2.2.3 Other Information Collected Automatically

3.1

Provide, Measure and Improve our Products and Services

3.2 Deliver Relevant Content and Recommendations

3.3 Deliver Advertising and Interest-Based Advertising

3.5 Contact You

3.6 Protect the Rights of RDN & Others

4.1

RDN Affiliates

4.1.2 Third party service providers

4.1.6 Authorities, regulators or government entities

4.1.7 Merger or acquisition entity

3, CN 4, and CN 5.5 Third parties who measure or deliver

Interest-based Advertising*

* We and select third parties use Advertising Cookies to choose and deliver ads we believe are relevant to you and your interests, understand their effectiveness, and conduct market research. This involves accessing information from your browser or device, such as advertising and device identifiers, and processing this and other Personal Data such as IP address. Advertising Cookies remember what you have looked at or purchased on our Services and other sites over time, and may be combined with other information received from third parties such as demographics.

** If you subscribe to the U.S. edition of Retail Daily News or Stepite's print publications, we may share your print mailing address with unaffiliated third party companies whose products and services may be of interest to you.

6.3.2.2 Notice of Financial Incentive

We may offer financial incentives to participate in certain surveys or focus groups. Details of the incentive, if applicable, including how to opt in or out and the basis for the value of the incentive, will be provided prior to your participation.

6.3.2.3 CCPA Privacy Rights

California residents may have certain rights under the CCPA, many of which are subject to limitations or exceptions under applicable law:

Right to Know

You may have the right to request the following information about the Personal Data or Other Information we may have collected about you during the past 12 months:

• the categories and specific pieces of Personal Data and Other Information we may have collected about you;

• the categories of sources from which we collected the Personal Data and Other Information;

• the business or commercial purpose for which we collected or sold the Personal Data and Other Information;

• the categories of third parties with whom we shared the Personal Data and Other Information; and

• the categories of Personal Data and Other Information we sold (per CCPA), or disclosed for a CCPA business or commercial purpose, and

• the categories of third parties to whom we sold (per CCPA), or disclosed for a CCPA business or commercial purpose, that information.

Right to Delete

You may have the right to request that we delete the Personal Data and Other Information we have collected from you.

Certain information may be exempt from such requests under applicable law. In addition, we may need to retain certain information for recordkeeping purposes and/or to provide our Services to you. If you submit a request to delete, you may no longer be able to access or use our Services.

Right to Nondiscrimination

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise CCPA Privacy Rights.

Do Not Sell/Right to Opt Out of Sale of Personal Data or Other Information

You have the right to opt out of the sale of your Personal Data and Other Information. Sale under California law may include sharing of Personal Data and Other Information with a third party for monetary or other consideration, such as allowing third parties to receive certain information including IP address and/or browsing behavior to deliver interest-based (also called targeted) advertising, or the sharing of a print mailing address with unaffiliated third party companies whose products and services may be of interest to you, as described in Section 4.1.4.

6.3.2.4 How to Exercise CCPA Privacy Rights

If you would like to exercise the Right to Know, Right to Delete, or Do Not Sell, you can contact Customer Service, send a Privacy Request using any of the methods detailed below in the Contact Us section, or use this link Do Not Sell My Personal Information. However, to exercise your Do Not Sell right to opt out of interest-based advertising, please use the link (because interest-based advertising is delivered using Cookies, this has to be a device-based action).

CCPA Privacy Right	Customer Service	Contact Us	Do Not Sell My Personal Information
Right to Know	√	√	√
Right to Delete	√	√	√
Do Not Sell My Personal Information: opt out of any CCPA “sale” not related to interest-based advertising	√	√	√
Do Not Sell My Personal Information: opt out of interest-based advertising (this has to be a device-based action)			√

For your protection, we may only implement requests with respect to the Personal Data or Other Information associated with the particular email(s) you provide in your Privacy Request, and we will take steps to verify your identity before granting access to your Personal Data or Other Information or complying with your Privacy Request. For example, we may verify your Privacy Request by matching information you provide with our records, or you may be asked to log in to your online account (if applicable). We may request additional information to verify your identity depending on the nature of the Privacy Request and the sensitivity of the information sought, if you do not have an account with us, or if we have reason to suspect the security of your account is compromised.

You can use an authorized agent to submit your Privacy Request. If you use an authorized agent, in addition to verifying the Privacy Request itself (see above), we will also verify the authorized agent’s ability to act on your behalf (they should submit written permission to act on your behalf or a power of attorney).

Once we have verified your identity (and your authorized agent, as applicable), we will respond to your Privacy Request as appropriate. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your Privacy Request. If we are unable to complete your Privacy Request in whole or in part, we will let you know why.

How We Have Responded to CCPA Privacy Requests

To learn how we responded to CCPA Privacy requests received during the prior calendar year, here.

7. OTHER IMPORTANT INFORMATION

7.1 Updates to Privacy Notice

RDN may periodically update this Privacy Notice without prior notice to reflect changes in our practices. Please look at the Effective Date at the top of this Privacy Notice to see when this Privacy Notice was last revised. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on the RDN Services. We will notify you by posting a prominent notice on the RDN Services indicating we have updated this Privacy Notice. Your use of the RDN Services or your provision of Personal Data to us following these changes means you acknowledge you have read and accept the revised Privacy Notice.

7.2 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 you do not wish to be tracked across websites over time. However, since no technology standard for DNT signals has been developed or adopted to date, RDN does not currently respond to DNT signals.

7.3 Transfers

Your Personal Data may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside your country of residence, including the United States, and may have different data protection laws than in your country.

If you are located in the EEA, we will implement appropriate safeguards to protect your Personal Data as required if we transfer it outside the EEA.

7.4 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 notice, rather than this Privacy Notice. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.

8. CONTACT US

If you have questions about this Privacy Notice or how we or our service providers handle your Personal Data, please contact our Chief Privacy Officer and Data Protection Officers at privacypolicy@dowjones.com.

Or you may write to:

Attention: Privacy

Stepite, LLC, 426 E. 1750 N. Unit B, Vineyard UT 84059, United States

If you are located in the EEA, the entity responsible for the collection and processing of Personal Data in connection with the RDN Services is Stepite, LLC (U.S.) (contact information provided above). If you have a corporate or group subscription agreement, the entity responsible for the collection and processing of your Personal Data is the entity with whom your company, professor or school has a direct relationship.

We will respond to your questions and complaints about our processing of your Personal Data. If you are not satisfied with our response, depending on where you are located you can contact a supervisory authority or your state’s attorney general. Please do not disclose any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, or trade union membership), social security numbers, or criminal background information when contacting us.