Yellowbook Inc.
Privacy Policy for Advertisers

Last modified: August 17, 2011.

In this privacy policy, we will refer to Yellowbook Inc. using the terms ‘Yellowbook’, ‘us’, ‘we’ and ‘our’. If we use the term ‘Yell Group’, this means us, our ultimate holding company and its subsidiaries. The term ‘our advertiser websites’ refers to any advertiser-focused websites that we own or run from time to time. If you advertise with us or use any of our advertiser websites, we call you an ‘advertiser’ and this policy applies to you. If you use any of our services, we call you a ‘user’ and you should refer to our privacy policy for users.

We are committed to protecting and respecting your privacy. This privacy policy is about the way we collect, use and process or otherwise handle the personally identifiable information (‘personal information’) of our advertisers.

Safe Harbor

This Safe Harbor privacy policy applies to all personal information we receive from the European countries that participate in the Safe Harbor Programs, as amended from time to time. Yellowbook complies with the US-EU Safe Harbor Privacy Framework, including the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement (the ‘Privacy Principles’). Yellowbook adheres to the Privacy Principles and is registered with the US Department of Commerce.

1 - The information we collect and how we collect it

To provide you with our products and services that you order, we need information about you.

If you use our advertiser-focused websites, you are in control of what information we collect about you, but if you choose not to share your information, you may not be able to access or use all or part of our advertiser websites.

We will collect information about you when you:

• use our advertiser websites, including by using cookies and other data storage devices;
• advertise with us;
• ask for a free listing entry (a listing of your business details which we will include in our services for free);
• order directories or any of our other products and services;
• apply for credit with us;
• register to use any of our advertiser-focused websites;
• register for, or attend, a seminar, conference, workshop, training course or networking event that we advertise and/or provide;
• set up, look at, or change your profile or account with us;
• ask for information from us;
• give us a testimonial or other feedback;
• enter competitions, prize draws or other special promotions;
• fill in surveys; or

speak to us on the telephone, including by recording the call.

We may also get information about you from third parties, with whom we have a business relationship, or for example if we need to check your credit rating or credit score before providing you credit to allow you to buy advertising. We also buy business information from other organizations, so we may get information about you from those organizations.

2 – How we use the information we collect about you

Whenever you give us your personal information, we will use it in accordance with the Privacy Principles.

a) When you order our products or services

If you advertise with us, ask for a free line entry, order our directories or any other products and services, register for or attend one of our events, apply for credit with us, set up, look at or change your account details or contact our customer service team, we will record your personal details. Your information will be used in the first place to provide the products, services or information you have asked for. We keep the information you provide and may use it for several purposes, including:

• accounting, billing and audit;
• credit checking or screening;
• credit, debit or other payment card verification and screening;
• debt collection;
• safety, security, administrative and legal purposes;
• analyzing statistics, the market and marketing information;
• developing, testing and maintaining systems;
• studies, research and development;
• advertiser or user surveys; and
• customer services and to help us in any future dealings with you, for example by identifying your requirements and preferences.

b) When you use our advertiser websites

When you give us information while using our advertiser websites, we will use it for the purposes set out in this privacy policy, on the data entry forms, in any relevant terms or conditions and on pages or emails which link to the data entry forms.

c) Cookies on our advertiser websites

We use cookies to help us make the services we offer on our advertiser websites better for all our advertisers. For example, cookies help the website to ‘remember’ that you are logged into the site. This information is stored only on your computer.

We also collect information on your activity while you use our advertiser websites, such as:

• your IP address (this is a unique 12 digit number used by programs on the internet to recognize and communicate with your computer);
• the type of browser you use (a browser is the program you use to look at websites, such as Internet Explorer, Firefox or Safari);
• the times when you access the site and for how long; and
• your referring URL (the site you came from to reach our website).

This information does not allow us to identify you. We collect it from lots of visitors to our advertiser websites and analyze it. This lets us build up a picture of how people use our advertiser websites. This helps us improve the services we offer.

We may also give anonymous statistics about users to other, reputable organizations, but the information we provide will not include details that would allow these organizations to identify you.

d) Tracking how our advertiser websites are used

We may collect information about activity on our advertiser websites, or we may use other organizations to collect it and to share the results with us. We use this information to:

• analyze statistics;
• track pages and paths used by visitors to, or users of, our online service;
• target the ads or offers, such as banners, on our advertiser websites and on the websites and other websites of other organizations; and
• track the use of our internet banner ads and other links from our marketing partners' websites to our advertiser websites.

For these purposes, we and the other organizations we use keep information on the path you take to get to our advertiser websites and on some of the pages you visit or use through our advertiser websites, using cookies, web beacons and other on-device storage. You cannot be personally identified from the information that we or these other organizations collect. For information about web beacons, or the organization we use (including how to decline their cookies), please read section 3(b) - Your choices for cookies and to manage them.

e) Third party advertisers and ad targeting;

We use third-party companies to serve ads and/or collect non-personally identifiable information when you visit our websites. These companies may use information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you on this site, other websites and other forms of media. These companies often use a cookie or third party web beacon to collect this information. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here.

f) Children’s Online Privacy Protections Act Compliance

Our websites are not designed to attract children under the age of 13 and we do not knowingly collect personal information from anyone under the age of 13.

g) When you talk to us on the telephone

We record and monitor calls for legal, security and training purposes and to improve the service we provide to you.

h) Testimonials

If you give us feedback, we may use it to improve our products and services and we may publish it online or offline to promote our business, products and services. We will ask for your permission before we publish it.

i) Direct marketing

We offer you the chance to receive important news from Yellowbook and information about our products and services, such as changes to the way you can use our advertiser websites and new products or services and special offers you might be interested in. For information on how to change your marketing preferences, please read section 3(a) – Your marketing choices and how to manage them.

j) Surveys

Every now and again, we may ask you how we are performing or for your opinion on our products and services. When we do surveys, we may use cookies or other on-device storage and may combine the information collected by those cookies or other on-device storage with your answers. We will make sure that the survey results do not identify you, or anyone else who fills in our surveys.

3 – Your choices and how to manage them

a) Marketing

If you are registered on one of our advertiser websites. You can change your marketing preferences at any time by viewing and updating your account profile through the myYellowbook feature of our advertiser website. You may request not to receive (i.e., "opt-out" of receiving) promotional email messages from us, by unchecking the checkbox beside the "I wish to receive updates and information from Yellowbook" line on the myYellowbook account registration page. If you receive a marketing email message from us, you may click on the “Unsubscribe” link contained in that email to opt out of receiving similar email messages in the future. You may also opt out of receiving marketing materials by contacting our Customer Service Department at 1.800.YB.YELLOW.

If you tell us that you do not want to receive direct marketing, we reserve the right to contact you in order to confirm and carry out any requests or orders you make and for administration purposes.

b) Cookies

If you do not want a website to create a cookie on your computer, most web browsers provide the option to disable them. However, our advertiser websites may not work properly if you reject our cookies. If you want to know more about how cookies work and how to manage or delete them, visit the World Wide Web Consortium's website or visit the Interactive Advertising Bureau's website.

4 – Who we may share your personal information with

We will only sell your personal information to a third party if you consent.

We may need to share your information with other organizations to provide you with the products, services or information you ask for. We may pass your information to one or more of the following organizations:

• other companies in the Yell Group;
• credit checking or screening service providers;
• payment processing organizations (such as PayPal);
• debt collection agencies;
• data processing companies, mailing houses and other third party suppliers working on our behalf;
• research students, universities and other research and development organizations; and
• government agencies, enforcement agencies and the police.

With respect to sharing information with third parties that are working on our behalf, we first either ascertain that the third party subscribes to the Privacy Principles or is subject to the European Directive on Data Protection or another adequacy finding or enters into a written agreement with the third party requiring that the third party provide at least the same level of privacy protection as is required by the relevant Privacy Principles.

If you advertise with us, we may share any business address you give us with your customers on a case by case basis if there is a genuine consumer dispute, and/or to comply with legal process.

Every now and again, we receive requests for information from government agencies, the police and other enforcement agencies, or other third parties through subpoena or other valid legal process. If this happens, and there is a proper legal basis for providing your personal information, we will provide it to the party asking for it.

5 – How we keep your information secure

We take the security of your personal information very seriously. We have put in place technology and security policies which are designed to protect the personal information that we hold about you. These cover storing, using and releasing any information you have provided, and preventing unauthorized access or use. We have put in place appropriate technical and organizational measures against unauthorized or unlawful processing of personal information and against accidental access, disclosure, alteration, loss or destruction of, or damage to, personal information. These include internal reviews or our data collection, storage, processing and destruction practices. We take steps to ensure the reliability of our personnel and subcontractors.

We use an internal self-assessment program to verify that this privacy policy is accurate, comprehensive, prominently displayed, implemented and accessible. The self-assessment program also is used to indicate that this privacy policy conforms to the Privacy Principles and that we have in place procedures for training employees in its implementation, disciplining employees for failure to follow it and periodically conducting objective reviews of compliance with the foregoing.

6 – Accessing and updating your personal information

a) Request not to use information

You can ask us not to use your personal information for marketing purposes. For more information, please read section 3(a) – Your marketing choices and how to manage them.

b) Access to information

You can ask to see information we hold about you, (with some exceptions). If you would like a copy of your personal information, you should contact our data privacy officer.

c) Keeping information up to date

We limit our collection of personal information to that which is relevant for the intended business and legal purposes for which it is to be used. We do not use the personal information in a way that is incompatible with the purposes for which it was collected or subsequently authorized by the individual. To the extent necessary for those purposes, we take steps to ensure that personal information is reliable for its intended use, accurate, complete and current.

You have the right to review and update your personal details. You can do this through the “My Business Center Account” section of our advertiser websites. We will delete your personal information at your request if it is not otherwise required to be retained by law or for legitimate business purposes. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

We will ask you to identify yourself and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.

7 – What to do if you have a complaint or concern

We (a) provide procedures for verifying that our commitments to adhere to the Privacy Principles have been implemented; (b) undertake obligations to remedy problems arising out of a failure to comply with the Privacy Principles; and (c) provide independent recourse mechanisms so that each individual's complaints and concerns regarding our handling of personal information under the Safe Harbor Program can be investigated and resolved and damages awarded where the applicable law or private sector initiatives so provide.

Yellowbook is committed to resolving any privacy concerns that you may have. If you have any concerns or complaints about the way we’ve handled your personal information, please contact our data privacy officer. We’ll try to resolve the complaints directly with you, if we can, but if we can’t we will cooperate with all appropriate regulatory authorities. We are also subject to the jurisdiction of the U.S. Federal Trade Commission. Individuals who are unable to resolve a complaint through complaint process may contact the Federal Trade Commission:

Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580
consumerline@ftc.gov
www.ftc.gov

8 – How to contact us about this privacy policy

We welcome your questions, comments and requests about this privacy policy. Please contact our data privacy officer.

9 – How we can make changes to this privacy policy

We may update this privacy policy from time to time so you may want to check it each time you give us personal information or use our advertiser websites. We will keep prior versions in an archive for your review. If you would like a copy of a prior version, please contact our data privacy officer.

10 – Conditions of Use

For information about the terms and conditions governing your use of our Site, please review our Conditions of Use at http://www.yellowbook.com/conditionsofuse.

© Yell Group plc, August 17, 2011