SAFE HARBOR

SAFE HARBOR PRIVACY POLICY

Time Inc. ("the Company") is committed to preserving personal privacy. As part of that commitment, the Company adheres to the Safe Harbor Principles administered by the United States Department of Commerce in consultation with the European Commission (the "Safe Harbor Program") with respect to personal information within the scope of this Safe Harbor Privacy Policy ("Policy"), pursuant to the European Commission's personal data directive (the "EU Personal Data Directive").[1]

Scope

This Policy applies to all personal information received by the Company in the United States from the European Economic Area ("EEA") or Switzerland that may be used for the following purposes and which resides on the Company’s, or its vendors’, databases and/or systems:

Employee Data:

Data concerning current and former employees and other workers for human resources functions, including administering employee contracts, employee evaluations, implementing employee-related actions and obligations and providing employment benefits and related information; compensation planning, including raises and bonuses/stock grants;
Payment services for vendors;
Incident management, technology requests, change management;
Authentication.

Consumer Data:

Data warehousing for business intelligence, analytics, marketing, product distribution, customer retention and acquisition;
Order acceptance, subscription fulfillment, customer service, payment processing, retention marketing, and cancel processing for magazines, digital products, goods, and services;
User-generated content tools, including message boards and commenting;
Extending and managing magazine subscriber access to digital products; and
Online subscription sales.

Definitions

"Agent" means any third party that processes personal information pursuant to the instructions of, and solely for the benefit of, the Company, or to which the Company discloses personal information for processing on the Company's behalf.

"Data subject" means, as to personal information, the natural person as to which such personl information relates. Under is Politcy, a data subject includes (i.) past, present, and prospective employees, their beneficiaries and dependants, and vendors of the Company and its subsidiaries, and (ii) active, former, and potential magazine customers whose data is sent from the EEA or Switzerland to the Company in the United States and resides on the Systems.

"Personal information" means any information relating to an identified or identifiable natural person that is within the scope of the EU Personal Data Directive, received by the Company from the EEA or Switzerland, and recorded in any form and residing on the Systems. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Personal information does not include anonymized information or aggregated information (to the extent an individual's identity cannot reasonably be derived from such information.

"Processing" of personal information means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

"Sensitive personal information" means personal information that reveals a natural person's race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns a natural person's sex life or health.

Safe Harbor Principles

The following principles are based on the Safe Harbor Principles. Additional information about the Safe Harbor Program is available on the U.S. Department of Commerce's website at http://www.export.gov/safeharbor.

Notice

Through this Safe Harbor Privacy Policy, the Company notifies individuals about the purposes for which it collects their personal information, and the types of third parties to which it may disclose their personal information.

Employees. On occasion, the Company transfers employee personal data to the Systems located in the United States in connection with the efficient management and operation of the Company, enabling all Company personnel to communicate with one another and work together, facilitating human resources and benefits administration, and safety and security processes. The Company may also transfer employee personal data to an agent of the Company in connection with the above purposes, such as a payroll provider or benefits provider. Data may also be processed and transferred to the United States in connection with collection and discovery requests in the context of litigation or government investigations, and in such context it may be made available to adverse parties in litigation or governmental entities.

Consumers. On occasion, the Company transfers consumer personal data to the Systems located in the United States in connection with the efficient management and fulfillment of goods and services. The Company may also transfer consumer personal data to an agent of the Company in connection with the above purposes, such as a printer. Data may also be processed and transferred to the United States in connection with collection and discovery requests in the context of litigation or government investigations, and in such context it may be made available to adverse parties in litigation or governmental entities.

Choice

Employees. Employees of the Company who reside in the EEA or Switzerland have the choice to opt-out of having their personal information disclosed to a third party that is not an agent or used for a purpose other than that for which it was originally collected as described in the "Notice" section above. Employees so desiring to opt-out should contact their Human Resources representative. Except as permitted by the Safe Harbor Principles, the Company does not use sensitive employee personal information for a purpose other than that for which it was originally collected, or disclose sensitive employee personal information to a third party that is not an agent of the Company, without the employee's opt-in to such use or disclosure, respectively.

Consumers. Consumers who reside in the EEA or Switzerland have the choice to opt-out of having their personal information disclosed to a third party that is not an agent or used for a purpose other than that for which it was originally collected as described in the "Notice" section above. Consumers so desiring to opt-out should contact Customer Service for the respective publication or other service from which they wish to opt out, or, alternatively, contacting us as described in the "How to Contact Us" section below. Except as permitted by the Safe Harbor Principles, the Company does not use sensitive consumer personal information for a purpose other than that for which it was originally collected, or disclose sensitive consumer personal information to a third party that is not an agent of the Company, without the consumer's opt-in to such use or disclosure, respectively.

This provision does not apply to public record information or publicly available information except in certain situations as defined by the Safe Harbor Program.

Onward Transfer

The Company will obtain reasonable assurances from its agents that they will safeguard personal information collected by the Company on behalf of consumers or employees consistently with this Policy and the Safe Harbor Principles. Examples of appropriate assurances may include: a contract obliging the agent to afford a level of protection to the personal information that is at least equivalent to the Safe Harbor Principles; Safe Harbor certification by the agent; or the agent being subject to EU Directive 95/46/EC or other law providing an adequate level of privacy protection.

This provision does not apply to public record information or publicly available information except in certain situations as defined by the Safe Harbor Program.

Access

Upon an individual's request, the Company will offer such individual reasonable access to his or her personal information and will afford such individual a reasonable opportunity to correct, amend, or delete inaccurate information. If a Company employee would like to access personal information maintained by the Company, the employee should make a written request to his or her local human resources representative. If a Consumer would like to access personal information maintained by the Company, the consumer should contact Customer Service for the respective publication or other service with which they have a relationship, or, alternatively, the Privacy contact provided at the end of this policy. For security purposes, the individual may need to provide the Company with various pieces of personal information to process the request. The Company may limit or deny access to personal information, or charge a fee, where providing such access would be unreasonably burdensome or expensive under the circumstances or as otherwise permitted by the Safe Harbor Principles.

Security

The Company will take reasonable technical, physical, and administrative measures, including training, to protect personal information from loss, misuse, and unauthorized disclosure, access, alteration, and destruction. The Company safeguards information according to established security standards and periodically assesses new technology for methods of protecting information.

Data Integrity

The Company (or its designee) will take reasonable measures to verify that personal information is relevant for its intended use, reliable for its intended use, accurate, complete, and current.

Enforcement and Dispute Resolution

The Company will conduct periodic assessments to confirm the accuracy of, and verify its adherence to, this Policy. The Company will investigate suspected infractions. Any employee who the Company determines to be in violation of this Policy will be subject to disciplinary action, which may include termination of employment.

Any questions, concerns, or complaints concerning the collection and use of personal information by the Company should be directed to the Privacy contact provided at the end of this policy. The Company will conduct a reasonable investigation of and will attempt to resolve any complaints in accordance with the principles contained in this Policy. For complaints that cannot be resolved between the Company and the complainant, the Company agrees to participate in the dispute resolution procedures of the panel established by the European Data Protection Authorities to resolve disputes pursuant to the Safe Harbor Principles.

Limitations

The Company's adherence to the Safe Harbor Principles may be limited by any applicable legal, regulatory, ethical or public interest consideration, and as expressly permitted or required by any applicable law, rule, or regulation. Examples of such limitations include but are not limited to exceptions to the opt‑in requirements for sensitive personal information permitted by Commission Decision 2000/520/EC of 26 July 2000, exceptions on access as permitted by Safe Harbor Principles, or under applicable European Economic Area member state or Swiss directives. The Company also may disclose personal information reasonably related to the sale or disposition of all or part of its business.

Modification of this Safe Harbor Privacy Policy

This Policy may be amended from time to time with or without notice in accordance with the Safe Harbor Principles. Any modified Policy will be posted on the Company's intranet.

How to Contact Us

If you are a consumer and you have any questions or concerns about the collection and use of personal information by the Company, pursuant to this Safe Harbor Privacy Policy, please contact us via email by clicking here or by writing to:

Time Customer Service

Attention: Consumer Affairs

3000 University Center Drive

Tampa, Florida 33612-6408

This Privacy Policy was posted August 30, 2012.

[1] Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.