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PRIVACY POLICY

Harvard Business Publishing (HBP) takes the privacy of its users seriously. HBP
has adopted information management guidelines for our customer relationships
designed to respect the privacy and preferences of our users.


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This Privacy Policy applies to all information collected from or about users of
our websites, applications ads, and commerce services owned or operated by HBP
(except as noted below). This Privacy Policy describes how and when HBP
collects, uses, and shares your information when you use our services and
website. For services and websites used by residents of the European Union,
Harvard Business School Publishing Europe Ltd and/or Harvard Business School
Publishing France SAS are the data controller(s) responsible for your personal
information.

All information collected will be handled with care in accordance with HBP's
information management guidelines and respect for your privacy. HBP endeavors to
comply with all laws and regulations that apply to the collection and use of
personal information, including but not limited to U.S. privacy laws and the EU
General Data Protection Regulation (GDPR).


QUICK GUIDE TO CONTENTS

 1. What Type of Information Does HBP Collect?
 2. How Does HBP Use Information About You?
 3. Does HBP Share Personal Information with Third Parties?
 4. How Long is Personal Information Retained For?
 5. How is Personal Information Secured?
 6. What are Your Rights and Choices?
 7. Does HBP Transfer Data Internationally?
 8. Contact Us


1. WHAT TYPE OF INFORMATION DOES HBP COLLECT?

There are several ways we may collect information from or about you, including
through (A) information you provide to us directly; and (B) information that we
automatically or passively collect.


A. INFORMATION YOU PROVIDE

The personal information collected by HBP may include:

 * Name, postal address, phone number, fax number, and e-mail address.
 * Financial account information, such as credit card number and other payment
   information. Please note, we do not retain credit card information.

We may also collect information about you such as:

 * If you create an account – your username, password, and other demographic
   information that you provide.
 * If you purchase from HBP – what you buy, and how frequently you buy.
 * If you take a survey or interact with us in various other ways – demographics
   information that you provide and information about subjects that may interest
   you.
 * If you connect your account to another service such as LinkedIn or Twitter,
   the other service may send us your registration or profile information on
   that service that you authorize. This information enables cross-platform data
   sharing to improve your user experience.


B. INFORMATION WE AUTOMATICALLY COLLECT

Whenever you visit or interact with the site, we, as well as any third-party
advertisers and/or service providers, may use cookies, web beacons, local shared
objects (Flash Cookies), or other technologies to automatically or passively
collect information about your online activity and website use information. For
information about our use of cookies and other similar technologies through the
site, you can read our Cookie Policy here.

Please note that we automatically collect the following information about you:

 * Website Use Information. We may automatically collect website use information
   when you visit our site. This may include information about your Internet
   service provider, your operating system, browser type, domain name, Internet
   protocol (IP) address, your access times, the website that referred you to
   us, the Web pages you request, and the date and time of those requests.
 * Third Party Service Providers. We may use third party service providers to
   support our website. Some of these service providers may use technology such
   as cookies, web beacons, pixel tags, log files, or Flash cookies to receive,
   collect, and store information.
 * Third Party Analytic Technologies. We may use third parties' analytics and
   tracking tools to better understand who is using the website, how people are
   using website, how to improve the effectiveness of the website, our services
   and related content, to help us or those third parties serve more targeted
   advertising to you across the Internet, and to allow "Like" buttons and
   "Share" buttons to work. These tools may use technology such as cookies, web
   beacons, pixel tags, log files, Flash cookies, HTML5 cookies, or other
   technologies to automatically collect and store certain information. They may
   also combine information they collect from your interaction with the website
   with information they collect from other sources. We do not have access to,
   or control over, these third parties' use of cookies or other tracking
   technologies.

To learn more about your advertising choices relating to the collection and use
of your information, please see the "What are Your Rights and Choices" section
below.


C. INFORMATION COLLECTED FROM OTHER SOURCES

We may acquire information from other trusted sources to update or supplement
the information that you provide or that we collect automatically. We may use
this information to help us maintain the accuracy of the information we collect,
to target our communications so that we can inform you of products, services or
other offers that may be of interest to you, and for internal business analysis
or other business purposes.


D. COMBINATION OF INFORMATION

We may combine the information we receive from and about you, including
information you provide to us and information we automatically collect through
our online services, as well as information collected offline, across other
computers or devices that you may use, and from third party sources.


2. HOW DOES HBP USE INFORMATION ABOUT YOU?

HBP may use the information we collect from and about you for a variety of
business purposes, including to:

 * Allow us to process orders, registrations, and customer service inquiries.
 * Communicate with you about your orders, purchases, accounts, and requests for
   information.
 * Provide you with information about products and services we offer (if you
   agree to receive such information).
 * Address problems with the website or our business, and to protect the
   security or integrity of the Site and our business.

We also use anonymous or aggregated information to allow us to audit site usage,
create marketing profiles, manage our relationship with advertisers, and to
provide support services to us. This processing may involve profiling – for
example to create audiences based on demographic or location-based information
for marketing and customization.

We will have a lawful basis for processing your data if:

 * We need to process your information in order to provide you with the products
   or service you have requested or to enter into a contract;
 * You have consented to such processing;
 * We have a legitimate interest for processing your data – e.g., for fraud
   prevention; network and information systems security; data analytics;
   enhancing, modifying or improving our services; identifying usage trends;
   and/or
 * We are legally obliged to process it.


3. DOES HBP SHARE PERSONAL INFORMATION WITH THIRD PARTIES?

We do not share your personal information except in the limited circumstances
described here. We may share your personal information with:

 * Our Affiliates: We may share your information with our affiliates and
   subsidiaries bearing the Harvard Business brand for business, operational,
   promotional and marketing purposes.
 * Third Party Service Providers: We may share your information with third party
   service providers that provide business, professional or technical support
   functions for us (including to the extent necessary or desirable to fulfill
   or ship your order or complete your transaction), help us operate our
   business and the website, or administer activities on our behalf.
 * School: If you access our content through an academic curriculum in your
   school or university, we may share personally-identifiable information about
   your progress, scores, results, logon and logoff times, and similar data with
   your school. We do not share this information with any outside entities other
   than your school.
 * Selected Advertisers: We sometimes work with advertisers or other third
   parties to serve ads targeted to your interests, or to collect data for
   conversion tracking (that is, what actions you take after you click on an
   ad).We do on occasion provide magazine subscribers' postal mailing addresses
   (but not your email address) to selected advertisers who wish to reach you by
   mail.
 * Legal Obligations; Safety: We may access and disclose your information to
   respond to subpoenas, judicial processes, or government requests and
   investigations, or in connection with an investigation on matters related to
   public safety, as permitted by law, or otherwise as required by law. We may
   disclose your information to protect the security of our site, servers,
   network systems, and databases. We also may disclose your information as
   necessary, if we believe that there has been a violation of our Terms of Use,
   any other legal document or contract related to our services, or the rights
   of any third party.
 * Sale or Transfer of Business or Assets: We may sell or purchase assets during
   the normal course of our business. If another entity acquires us or any of
   our assets, information we have collected about you may be transferred to
   such entity. In addition, if any bankruptcy or reorganization proceeding is
   brought by or against us, such information may be considered an asset of ours
   and may be sold or transferred to third parties. Should such a sale or
   transfer occur, we will use reasonable efforts to try to require that the
   transferee use personal information provided through our services in a manner
   that is consistent with this Privacy Policy.
 * Aggregate or Anonymous Non-Personal Information: We may also share aggregate,
   anonymous, or de-identified non-personal information with third parties for
   their marketing or analytics uses.


4. HOW LONG IS PERSONAL INFORMATION RETAINED FOR?

We will keep your personal data for as long as we need it for the purpose it is
being processed for. For example, we will retain your information for as long as
your account is active or as needed to provide you services; and after that, we
will keep the personal information for a reasonable period of time, which
enables us to handle or respond to any complaints, queries or concerns relating
to your account.


5. HOW IS PERSONAL INFORMATION SECURED?

HBP maintains appropriate physical, technical and administrative security to
help prevent the loss, misuse, unauthorized access, disclosure or modification
of personal information.

While we take these steps to protect your personal information as much as we
reasonably can, no system or transmission of data over the Internet or any other
public network, or any storage of data, can be guaranteed to be 100% secure.


6. WHAT ARE YOUR RIGHTS AND CHOICES?


A. YOUR RIGHTS

We respect your privacy rights and provide you with reasonable access and rights
to the personal data that you may have provided through your use of the website
and services. You may update, amend, or delete your account information and/or
preferences at any time by:

 * Following the opt-out instructions in promotional emails we send you.
 * Signing in to your HBP account, if you have one, and visiting the Account
   Settings section within My Library to manage your preferences and to update
   your personal information.

If you live in the European Economic Area (EEA), you may have additional rights
under applicable data protection laws. If you wish to exercise those rights,
please contact us as set forth in the "Contact Us" section. At any time, you may
object to the processing of your personal data, on legitimate grounds, except if
otherwise permitted by applicable law. If you believe your right to privacy
granted by applicable data protection laws has been infringed upon, please
contact us as set forth in the "Contact Us" section. You also have a right to
lodge a complaint with data protection authorities.

Please note that if you make any changes or update your account, these will be
reflected in active user databases within a reasonable period of time; however,
we may retain certain data when we have a legal obligation or lawful basis to do
so.

You may decline to share certain personal data with us, in which case we may not
be able to provide to you some of the features and functionality of the website.


B. COOKIES, TRACKING OPTIONS AND CALIFORNIA DO NOT TRACK DISCLOSURES

For California Residents: Certain parts of our Site require cookies. You are
free to set your browser or operating system settings to limit certain tracking
or to decline cookies, but by doing so, you may not be able to use certain
features on the Site or take full advantage of all of our offerings. Please
refer to your Web browser's or operating system's website or "Help" section for
more information on how to delete and/or disable your browser or operating
system from receiving cookies or controlling your tracking preferences.
Our system may not respond to Do Not Track requests or headers from some or all
browsers. We may use cookies or other technologies to deliver more relevant
advertising and to link data collected across other computers or devices that
you may use. To understand your choices for receiving more relevant advertising
or to manage your settings, please review the information below:

 * To learn more about the use of cookies or other technologies to deliver more
   relevant advertising and to know your choices with respect to collection and
   use of the data by these third party tools, you may visit the Digital
   Advertising Alliance's (DAA) opt-out page at
   http://www.aboutads.info/choices, or the National Advertising Initiative's
   (NAI) opt out page at http://www.networkadvertising.org/choices/.
 * On your mobile device, you may also adjust your privacy and advertising
   settings to control whether you want to receive more relevant advertising.


C. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may request information about our
disclosure of personal information to third parties or affiliated companies for
their direct marketing purposes. To make such a request, please contact us as
set forth in the "Contact Us" section. You must put the statement "Your
California Privacy Rights" in the subject field. We are not responsible for
notices that are not labeled or sent properly, or do not have complete
information.

Non-affiliated third parties are independent from HBP and if you wish to receive
information about your disclosure choices or stop communications from such third
parties, you will need to contact those non-affiliated third parties directly.


7. DOES HBP TRANSFER DATA INTERNATIONALLY?

HBP is a global business and we, or our service providers, may process,
transfer, and store information about our users on servers located in a number
of countries, including the United States and the European Economic Area (EEA).
Since we are committed to protecting your information, we take steps to ensure
that there are appropriate safeguards in place when we transfer that data. For
data transferred from the EEA to HBP or its service providers outside the EEA,
HBP relies on the EU Model Clauses (issued by the European Commission) to
provide an adequate level of protection. To request a copy of these EU Model
Clauses contact us as provided below.


8. CONTACT US

If you have any questions, comments, or concerns about our Privacy Policy,
please contact us at:

Harvard Business Publishing
20 Guest Street, Suite 700
Brighton, MA 02135 USA
Email: customerservice@harvardbusiness.org
Phone: (800) 988-0886 or (617) 783-7500

If you are a user located in the European Union, please contact us or our Data
Protection Officer at:

Harvard Business School Publishing Europe Ltd.
Vernon House
23 Sicilian Avenue
London WC1A 2QS
United Kingdom
Email: Data.Protection@harvardbusiness.org

or

Harvard Business School Publishing France SAS
23 Rue du Roule
75001
Paris, France
Email: Data.Protection@harvardbusiness.org

Designee's Public Contact Information:

Harvard Business School Publishing Europe Ltd.
Vernon House
23 Sicilian Avenue
London WC1A 2QS
United Kingdom
Email: Data.Protection@harvardbusiness.org
Steve Boucher, Director, Global Treasury and International Operations, Finance

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ROQ.AD INC.

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INDEX EXCHANGE, INC.

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QUANTCAST

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SOVRN HOLDINGS INC

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RTB HOUSE S.A.

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THE TRADE DESK

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ADMETRICS GMBH

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AMOBEE INC.

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EPSILON

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YAHOO EMEA LIMITED

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ADVENTORI SAS

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TRIPLELIFT, INC.

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XANDR, INC.

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NEORY GMBH

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TABOOLA EUROPE LIMITED

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SMART ADSERVER

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