Online Products

World Trade Press (“World Trade Press,” WTP,” “we,” “us,” or “our”) operates and hosts a number of online information products including (but not limited to):

• ABC Lingo Lite
• ABC Maps Online
• ABC the USA
• ABC the World
• ABC World Food
• ABC Food America
• AtoZ Food America
• AtoZebra Language
• AtoZ Maps Online
• AtoZ the USA
• AtoZ the World
• AtoZ World Business
• AtoZ World Culture
• AtoZ World Food
• AtoZ World Trade
• Food Passport
• America is Cooking
• Global Business Traveler
• Global Local Living
• Global Road Warrior
• Lingo 123
• Lingo Lite
• World Trade REF
• Global-Assignment

and related online programs and mobile applications (collectively, the “Online Services”), each of which is subject to this Privacy Policy and may be subject to additional platform-specific terms.

Products Operated and Hosted from the United States of America

World Trade Press Online Services are operated and hosted from the United States of America. Access to our Online Services is restricted to individuals and institutions who have accepted our Terms of Use. If you choose to access any of the Online Services from locations outside the United States of America, you do so at your own risk and subject to the laws of the United States of America which may differ from privacy laws in your state, province or home country, and you are responsible for compliance with any local laws. By submitting your personal information to us, our distributors, licensees, or agents through the use of the Online Services, you consent to the transfer of your personal information to any country and its use and disclosure in accordance with applicable U.S. federal and state laws and with this Privacy Policy. You may not use or export anything (including information) from the Online Services in violation of U.S. export laws, regulations or the Terms of Use.

Introduction to our Privacy Policy

World Trade Press is concerned about the privacy of information shared through our Online Services. We have created this Privacy Policy to let you know how we collect, use and safeguard the information that is collected and used on the Online Services. Our privacy practices are guided by the United States' Children's Online Privacy Protection Act of 1998, as well as data privacy laws in the United States and other applicable countries. Children under thirteen (13) years of age should always check with their parents or guardians before entering information on any website, including the Online Services, and we encourage families to discuss their household guidelines regarding the online sharing of personal information.

It is our policy to protect your personal information and to use it only in accordance with this Privacy Policy. This Privacy Policy only governs our use and disclosure of information collected through our Online Services, and works in conjunction with the Terms of Use, but does not modify or supersede them. Using our Online Services is voluntary, and by accessing or using our Online Services, you: (i) acknowledge that you have read and understood this Privacy Policy; (ii) agree that your access and use of the Online Services are subject to this Privacy Policy and the Terms of Use; and (iii) consent to our collection and use of your non-personal and personally identifiable information as described in this Privacy Policy, as updated or revised from time to time. At all times, we must reserve the right to disclose any information, including personally identifiable information, to comply with any applicable law, regulation, legal process or government request; to protect our rights and our property (including, without limitation) in the event of transfer of control of the company or substantially all of its assets), or during emergencies when safety is at risk, or for credit fraud protection and risk reduction purposes.

Modifications

World Trade Press may change this Privacy Policy at any time, consistent with the terms set forth in the Terms of Use, by posting the changed or amended Privacy Policy on the Online Services and updating the “Effective Date” set forth below. Your continued use of our Online Services following the posting of any changes to this Privacy Policy will signify your acceptance of any such changes or amendments. Therefore, we encourage you to check our Privacy Policy whenever you use our Online Services to see if it has been updated since your last visit.

Privacy Policy Limited to the Online Services

This Privacy Policy is specific to our Online Services and applies only to our Online Services and does not apply to activities that are "offline" or unrelated to the Online Services, including activities occurring on other websites that we operate. You should note that different privacy policies may apply to other parts of World Trade Press’ web presence.

Types of Information Collected

Several types of data are collected from you when you visit our Online Services, including:

• (i) personally identifiable information,
• (ii) non-personal information, and
• (iii) financial information (only in connection with our e-commerce websites)

Personally Identifiable Information (PII) The majority of World Trade Press Online Services do not ask the user for Personally Identifiable Information.

However, a few of our Online Services offer you the option of establishing a personal or user account (not associated with any financial transaction). Examples include, but are not limited to: ABC World Food, AtoZ World Food, and Food Passport. In these specific instances the user has the option of establishing a user account to collect and organize recipes. In other situations, the user may elect to register for participation in a chat or message board.

In such situations we may ask you to provide personally identifiable information, which may include:

• your first name,
• a user name and password (for account administration),
• an email address,
• one or several answers to security questions, so we can retrieve your password in the event you have forgotten it; and
• device ID, including IP address.

Some of this information may be gathered when you send us feedback or an email, when you disclose your email address as stated previously, when you register for certain services, when we set cookies, or directly in response to inquiries on the Online Services.

We may also sometimes collect information on your preferences based upon searches that you conduct through the Online Services. In all such cases you choose whether to provide us with such information; however, certain portions of the Online Services may not be available to you if you do not provide the information requested. By providing such information, you consent to our collection and use of it, as described in this Privacy Policy; however, World Trade Press does not require you to disclose more information than is reasonably necessary to use a feature or functionality of our Online Services as a condition of participation.

Non-Personal Information We automatically collect certain anonymous data regarding usage of our Online Services. The anonymous data we collect may include but is not limited to such information as:

• The name of the internet domain you used to access the internet,
• The IP address of the Online Services from which you linked to our Online Services,
• The date and time you accessed our Online Services,
• The type of web browser you are using, and
• The pages on the Online Services that you visited.

This information does not personally identify users, by itself or in combination with other information. We use this information to monitor the effectiveness of our Online Services and to consider potential changes to improve the user experience. Non-Personal Information may be collected through cookies. For more detailed information on cookies, please refer to the “Use of Cookies” section below.

Other Information Not Collected The majority of our Online Services do not require you to disclose, nor require us to request or collect, any credit card or other financial information, or any other personally identifiable information not described above, such as last name, home contact information, date of birth, Social Security number, or other similar non-public information. We do not request, solicit or intend to collect any such information and you should not disclose, enter or upload any such information on the Online Services. If we discover that such information was disclosed by you, we will exercise commercially reasonable efforts to delete such information; however, we are not liable for any consequences relating to such disclosures of information.

Information Collected for an E-Commerce Transaction The majority of our Online Services are made available to institutions and individuals on a licensed basis where the institution makes payment directly to World Trade Press via bank check or bank wire. Several of our Online Services, however, are made available to institutions and individuals through an e-commerce portal. In such cases we ask only for that information required by our credit card merchant account providers, PayPal, or other online payment provider to complete the transaction. This information typically includes:

• The buyer’s full name,
• he buyer’s email address,
• The buyer’s postal code,
• Credit card or PayPal account number,
• Credit card month and year of expiry,
• Credit card security code, and
• Other information as may be required to complete the transaction

However, other than the buyer’s name and email address, World Trade Press does not itself collect or maintain any of the financial-related information listed above. All such transactions are completed through encrypted and secure protocols with our credit card merchant account provider(s), through PayPal or other payment provider.

World Trade Press itself never comes into contact with, or maintain, any of the specific account information listed above.

Personal Information from Children We do not knowingly collect personal information from children under the age of thirteen (13) without the consent of their parents or guardians. For users less than thirteen (13) years of age, your parent or guardian can review the PII that we collect, ask to have it deleted and refuse to allow any further collection or use of such PII. For more information, or to exercise such rights, please contact World Trade Press using the contact information provided below.

Use and Disclosure of Information Collected

Our use and disclosure of certain information varies with respect to the type of information collected, including: (i) Personally Identifiable Information; and (ii) Non-Personal Information.

Personally Identifiable Information (PII) World Trade Press uses PII collected through our Online Services in conjunction with products and services offered and to respond to your requests for information on products or services. Additionally, we may use your email address to communicate with you regarding your account information only; accordingly, such communications do not constitute marketing. We may also combine such information with similar information for other users to create aggregate reports, which may be shared with your school, institution or other organizational subscriber and utilized internally by World Trade Press. In all cases, information included within such aggregate reports is not individually identifiable.

World Trade Press will not sell your PII to any third parties for marketing purposes. Though we make every effort to preserve your privacy, disclosure of your information to third parties for non-marketing purposes may occur in certain situations such as: (i) responding to a subpoena, court order or other such request; (ii) responding to a law enforcement agency's request or as otherwise required by law; and (iii) providing your information to a third party if there is a transfer of the assets or ownership in connection with proposed or consummated corporate reorganizations, such as mergers, acquisitions, or sales of business units. In all such instances, we will take the utmost care to disclose only that information which is necessary and appropriate under the circumstances. Additionally, we may share personal information with third-party vendors who assist us in performing internal functions necessary to operate our business. We require our third-party vendors to keep such information confidential and to only use the information for the purpose it was provided.

Personally Identifiable Information after Institutional Cancellation The situation may come up where individuals have established a user account on one of our Online Services under the umbrella of an institutional or organization license AND that institution or organization allows their license to lapse. To protect the continuity of such user accounts we will use the user’s email to notify such individuals of the status of their account and that they are eligible for an individual subscription to the Online Service at a 50 percent discount from the then current regular (retail) subscription rate.

Non-Personal Information We use the Non-Personal Information collected through the Online Services for statistical purposes and for improving the functionality of the Online Services. In general, this information is used internally but we may, from time to time, engage a third party’s software or services to assist us with these analyses. In those limited cases, disclosure of this information to a third party is necessary; however, the data remains anonymous at all times.a

Visibility of Your Personally Identifiable Information

If you chose to publish information on our Online Services (such as on a message or chat board) it may be viewed by other users of the Online Services. We are not able to monitor, control, or prevent others from copying, modifying, transmitting, sharing or otherwise further disseminating such information that you have posted in an interactive area of the Online Services. We do not ensure, warrant or guarantee the security of any information that is disclosed in such a way online, so you should consider carefully whether you are comfortable sharing such information in light of the risks.

Use of Cookies

Cookies are small bits of data cached or stored on your computer based on internet activity. We may use cookies to monitor individual activity in aggregate to improve the Online Services and provide features that are tailored to your needs. The information we gather may include IP address, user language, the operating system, browser type, the presence/absence of “flash” plug-ins, screen resolution, connection type, and information that identifies the cookie. Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent this. If you disable cookies, your ability to use some features of the Online Services may be limited.

We also use session cookies when you visit our Online Services. Session cookies are active only during the period you are logged on to our Online Services, and are removed when you leave. They help us track the sections of the Online Services that you use to allow us to make improvements in keeping with observed user preferences. This information helps us identify content and services that may be of interest to our users as we work to make further improvements to the Online Services.

Linked Online Services

We may provide links on the Online Services to other sites of interest; however, we do not review or endorse the content of these sites, and are not responsible for that content or the privacy policies of websites to which our Online Services link. If you provide any information to such third parties, different rules regarding the collection and use of your personal information may apply. We strongly suggest you review such third party's privacy policies and terms of use before providing any data to them. You should contact these entities directly if you have any questions about their use of the information that they collect.

Security; No Liability

World Trade Press has implemented multiple tiers of security measures to help protect against the risk of loss, misuse and alteration of any information under World Trade Press’ control. Personally Identifiable Information provided to World Trade Press is encoded using commercially appropriate technology, consistent with industry standard encryption protocols that protects data as it travels over the Internet, provided your browser supports it. Nevertheless, such security measures may not prevent all loss, misuse or alteration of information on the Online Services, and World Trade Press and its third-party licensors are not responsible for any damages or liabilities relating to any such security failures.

Your California Privacy Rights

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits users who are California residents to request and obtain from providers once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to:

Questions

If you have any questions or concerns about this Privacy Policy or the use of your information, or to modify or update any information we have received, please contact us through the Online Services or by physical or electronic mail addressed to:

Effective Date: December 11, 2017