PRIVACY NOTICE

Updated: January 1, 2020

American Greetings respects your privacy and is committed to protecting your Personal Information while providing a fun and safe online experience. Through our products and services, we want to serve and delight consumers every single day by providing creative and meaningful ways to socially connect and make the world a more thoughtful and caring place.

This Privacy Notice applies to all websites, mobile applications or apps, social features or networking, online services, widgets, downloads, or other outlets (the Platform or Service) that are owned or controlled by American Greetings and that post or include a link to this Privacy Notice, regardless of whether accessed by computer, mobile device, or otherwise. The Platforms for our products and services include, but are not limited to websites and apps found at: americangreetings.com, justwink.com, smashups.com and bluemountain.com, operated by AG Interactive, Inc., a wholly-owned subsidiary of American Greetings.

PURPOSE OF THIS PRIVACY NOTICE

This Privacy Notice explains how we look after your Personal Information whenever that information is provided to us. This includes when you request information from us, contact us (or we contact you), buy products and services from us, use the Platforms, or connect with us via social media or link to or from our websites. It also tells you about your privacy rights and how the law protects you. It has been updated to include additional data protection requirements for residents of the European Union (EU), United Kingdom, Liechtenstein, Switzerland, Norway or Iceland under the General Data Protection Regulation (GDPR), and other relevant data protection laws, including the California Consumer Privacy Act (CCPA).

This notice forms part of our Terms of Service. It should also be read in connection with our Cookie Policy and any other applicable policy posted in connection with or linked to our Platforms.

By accessing and otherwise using the Platforms, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice, and agree to the applicable Terms of Service, which are incorporated by reference. If you do not agree, please do not access or use our Platforms or otherwise provide us with your Personal Information.

SUMMARY

For ease of navigation, you can click on one of the links below to jump directly to the listed section.

WE FULLY DESCRIBE OUR PRIVACY PRACTICES WITH RESPECT TO THE PLATFORMS BELOW IN THIS PRIVACY NOTICE. THIS SUMMARY HIGHLIGHTS IMPORTANT INFORMATION REGARDING OUR COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION, AND REGARDING THIRD PARTIES WHO MAY COLLECT CERTAIN INFORMATION WHEN YOU USE THE PLATFORMS. PLEASE REVIEW OUR FULL PRIVACY NOTICE BEFORE USING OUR PLATFORMS.

• We primarily use the information we collect in connection with your relationship with our family of American Greetings' brands and to provide a more tailored experience for you on our Platforms, including your interactions with customer service. Some of our Platforms may request location information, and we typically use that information to notify you of stores or American Greetings' branded products near you. For more information visit, how we use the information we collect.
• The Platforms collect certain information regarding how you access and use the Platforms, and we may utilize third parties to collect and analyze this information on our behalf. For more information visit, the information the Platforms automatically collect.
• We will not rent or sell to or share your Personal Information with third parties or nonaffiliated American Greetings' companies, except to provide the products and services you've requested or without your specific consent. For more information visit, how and when we disclose information to third parties.
• The Platforms may contain content served by third parties, and we work with third-party service providers to conduct analytics. These third parties may collect certain information about your use of the Platforms or other websites or apps. These third parties may set and access their own tracking devices (including cookies, web beacons, and embedded scripts) and may otherwise collect or have access to information about you and your online activities. Some of these companies are members of the Network Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit here or about ads, which provide information regarding targeted advertising and offers an "opt-out" by participating companies. For more information visit, third party analytics and advertising service providers; online tracking.
• We may offer certain Social Networking Features on or through the Platforms, which may allow you to share information or make certain information public. For more information visit, social networking features; public information.
• Effective of January 1, 2020, California residents have expanded privacy rights under the CCPA as outlined in this Privacy Notice, and Section VIII (F), California Residents - PRIVACY NOTICE.

TABLE OF CONTENTS

1. INFORMATION COLLECTION
   1. Information You Provide
   2. Information the Platforms Automatically Collect
      1. Cookies
      2. Web Beacons and Pixels
      3. Location-identifying Technologies
      4. Embedded Scripts
   3. Do Not Track
   4. Information You Provide About Third Parties
   5. Information Third Parties Provide About You
2. HOW WE USE THE INFORMATION WE COLLECT
3. HOW AND WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES
   1. General Statement Regarding Information Sharing
   2. Third-Party Service Providers
   3. When You Agree to Receive Information from Third Parties or Request That We Share your Information
   4. Contests, Sweepstakes and Promotions
   5. Sharing Between American Greetings Companies; Business Transitions
   6. Administrative and Legal Reasons
4. THIRD PARTY ANALYTICS AND ADVERTISING SERVICE PROVIDERS; ONLINE TRACKING
5. THIRD PARTY CONTENT AND LINKS TO THIRD PARTIES
6. SOCIAL & INTERACTIVE FEATURES; PUBLIC INFORMATION; RETENTION
   1. Community Forums
   2. Social Networking Features; Public Information
   3. Contact Importers
   4. Testimonials
   5. Data Retention
7. YOUR LEGAL RIGHTS
8. OTHER MATTERS
   1. Privacy Shield Compliance
   2. Children's Privacy
   3. Data Security
   4. Changes to the Privacy Notice
   5. Consent to Transfer
   6. California Residents - PRIVACY NOTICE
   7. Nevada Residents Rights
9. CONTACTING US; EU REPRESENTATIVE

1. INFORMATION COLLECTION

   1. Information You Provide

      The Platforms may request that you provide certain personal information, which is information that may reasonably be used to identify you as a specific individual, directly or indirectly (Personal Information). It does not include information where your identity has been removed, deidentified or made anonymous. We may collect, use, store, and transfer different kinds of Personal Information, which we have grouped together as follows:

      Identity Data includes first name, last name, username or similar identifier.
      Contact Data includes billing address, home address, email address and telephone numbers.
      Financial Data includes payment card details, zip code, expiration date, and security code (collected and tokenized by our payment processor).
      Transaction Data includes details about products and services you have bought from us, and details about your purchase history, including payments received, and when you have requested information or asked questions, communication and call data, including with customer service, membership dates, card-sending history, including Recipient Data (defined below) and personal messages or sentiments that you enter for card sending.
      Profile Data includes your username and password, products and services bought by you, information about your preferences, interests, inquiries, feedback, and survey responses, and demographic information (including, your gender, ZIP code, or marital status).
      Recipient Data includes the first name, last name, email address, or significant dates (such as birthdays or anniversaries) that you provide for card sending.
      Usage Data includes information as to how and where you use our Platforms.
      Marketing and Communications Data includes your preferences as to whether you are happy to receive marketing from us.
      

      The Platforms may also enable you to transmit files or otherwise provide information to American Greetings. Please note that files you transmit may contain metadata, which may contain Personal Information. For example, photos you transmit could include metadata indicating where (e.g., GPS coordinates) and when (date and time) the photo was taken.

      We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information but is not considered Personal Information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. If we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information, which will be used in accordance with this Privacy Notice.

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   2. Information The Platforms Automatically Collect

      We and our third-party service providers collect certain information about your use of our Platforms (Usage Data). Usage Data may include the browser and operating system you are using, the URL, advertisements, or search terms that referred or otherwise led you to the Platforms (if applicable), aspects of the Platforms that you use or visit, the products or services you access or view, the types of greeting cards that you send, and the time of day you accessed the Platforms, among other information.

      Usage Data also includes the IP address or other unique identifier (Device Identifier) for any computer, mobile phone or other device (any, a Device) used to access the Platforms. A Device Identifier is automatically assigned to your Device, and our servers identify your Device by its Device Identifier. Please note that your IP address is included in the header information of every ecard notification email that we send for your ecards. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of a Device used to access the Platforms. Usage Data is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information in accordance with this Privacy Notice.

      The methods used to collect Usage Information may include:

      1. Cookies

         A cookie or local storage is a data file placed on a Device when it is used to visit a Platform or otherwise access our online content. Cookies may be used for many purposes, such as remembering you and your preferences and tracking your visits to the Platforms. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. You can find more information about cookies and how they work by visiting the website allaboutcookies.org.

         A Flash Cookie is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. Flash cookies may be used for various purposes, such as enabling a Flash feature and remembering your preferences. Flash cookies may not be deleted when you delete other types of cookies from a Device. For more information about Flash and the privacy choices Adobe offers, visit macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.

         If you choose to disable cookies on your Device, some features of the Platforms or our content may not function properly. In order to enjoy the Platform fully, below is information about one such vendor we use across one or more Platforms.

         Google Analytics

         We use Google Analytics for aggregated, anonymized website traffic analysis. In order to track use of our Platforms, Google drops a cookie (_ga) with a randomly-generated ID in your browser for logged-in users (a UserID). This UserID is anonymized and contains no identifiable information like email, phone number, or name. We also send Google your IP Address. We use Google Analytics to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving overall user experience and determining the Platform effectiveness. You can learn about Google's practices by going to google.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout. This opt-out feature, however, only works on your desktop browser and not on a mobile device. For mobile apps, you may be able to limit certain advertising practices using the settings on your phone, tablet or other mobile device. You may also download the AppChoices app at https://youradchoices.com/appchoices to opt out of the delivery of interest-based advertisements in participating mobile apps.

         Our Platforms use other third-party performance and remarketing cookies, and further information on those third-party cookies is located in our Cookie Policy or can be obtained by contacting us at help@americangreetings.com.

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      2. Web Beacons and Pixels

         Small graphic images or other web programming code called web beacons (also known as pixel tags, 1x1 GIFs, or clear GIFs) may be used on the Platforms or in our emails and may be invisible to you. Web beacons may be connected to your Personal Information, if you have provided it. Web beacons may be used for various purposes, such as counting visitors to the Platforms, monitoring how users navigate the Platforms, counting how many emails that were sent were actually opened, or counting how many times a link was accessed.

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      3. Location-Identifying Technologies

         The Platforms may also use global positioning systems (GPS) software and other location-based technologies, such as iBeacons, to locate you so we may verify your location, deliver you relevant content based on your location, as well as allow you to share your location to others as part of the Services we provide. We may determine your approximate or exact location information to provide location-based services. In addition to traditional GPS location-based services, some of the retailers and others we work with may install other types of location-tracking technology. These technologies emit a signal that we can use to detect to pinpoint your proximity to those locations (such as, how close you are to retail locations and products) or otherwise interact with the Platform (such as to send you helpful information, offers, and discounts).

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      4. Embedded Scripts

         An embedded script is programming code that is designed to collect information about your interactions with the Platforms, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Platform, and is deactivated or deleted thereafter.

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   3. Do Not Track

      Do Not Track (DNT) is a preference available in many web browsers that allow you to inform websites that you visit that you do not want them collecting information about you. The Platforms do not currently support recognition of DNT signals sent by a browser, which means we may collect information about you. We operate, however, as described in this Privacy Notice whether or not a DNT signal is received. For more information regarding DNT you can visit https://allaboutdnt.com.

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   4. Information You Provide About Third Parties

      The Platforms may permit you to provide Personal Information about third parties (Recipient Data), such as mailing address, email addresses, or significant dates (such as birthdays or anniversaries). If you use the Platforms to send an ecard, paper card, gift card, or any other content, we collect certain Personal Information about the recipient (such as name, mailing address, and email address, as applicable). We may share the information regarding your transaction with third parties as necessary to process your transaction (i.e., to create, send or deliver the card). If you choose to provide Recipient Data we will store that information only in connection with your relationship with us (e.g., to send greeting cards).

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   5. Information Third Parties Provide About You

      We may receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from American Greetings, the other website will forward your contact and other information to us so that we may contact you as requested. Further, we may receive certain information about you from third parties if you engage the third parties in connection with our Platforms -- for example, if you download one of our apps from an app store, make an in-app purchase, connect via Social Networking Features, or make a payment using a third-party payment provider like PayPal, consistent with the privacy policies of the applicable third parties.

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2. HOW WE USE THE INFORMATION WE COLLECT

   We will only use your Personal Information for business purposes when and where the law allows us. We use information about you, including Personal Information, to: (1) allow you to use the Platforms or to provide related customer service; (2) provide or offer you information, products, or services where we need to perform the contract we are about to enter into or have entered into with you; (3) send or display special offers or advertisements from AG Companies (defined in Section III E) and our business partners; (4) process your registration or requests, including verifying that information you provide is active and valid; (5) process a transaction you initiate; (6) improve the Platforms and our products, and for internal business purposes, including the measurement of the Platforms' effectiveness; (7) contact you with regard to your use of the Platforms and, in our discretion, changes to our policies; (8) identify and protect against fraudulent activities, transactions, and abuse of the Platforms, and to protect the rights and property of American Greetings, its partners, and customers and where it is necessary for our legitimate interests (or those of a third party); and (9) as otherwise described in this Privacy Notice, for purposes disclosed at the time you provide your information, or with your specific consent.

   When we refer to legitimate interests we mean the interest of our business in conducting and managing our business to enable us to give you the best service and products. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

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3. HOW AND WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES

   1. General Statement Regarding Information Sharing

      We do not rent, lease or sell your Personal Information to third parties for money or their direct marketing purposes. We may disclose your Personal Information for the following purposes: (i) if you direct us to share Personal Information; (ii) to comply with your requests; (iii) as part of a Business Transition; and (iv) as otherwise required or permitted by applicable law. We may also share non-Personal Information, including non-identifying Aggregated Data, with third parties at our discretion.

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   2. Third-Party Service Providers

      We may share Personal Information with our service providers who perform services for us or on our behalf; and in some instances, our service providers may collect information from you directly. Such services may include, for example, hosting or maintaining the Platforms, providing customer support, monitoring the Platform, data storage or warehouse, sending email, direct mail or other communications, fulfilling orders, mailing paper cards or sending gift cards, providing marketing assistance, research or business intelligence services, providing analytics services product safety or testing, processing payments or transactions, printing services, or performing other administrative services. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract or complying with legal requirements.

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   3. When You Agree To Receive Information from Third Parties or Request That We Share Your Information

      We may offer the opportunity to receive information or marketing offers from one or more third parties, or to otherwise have your information shared with a third party. We may also offer you the opportunity to order products and services from a third party directly through the Platforms or in communications you may receive from American Greetings; and in this case, we will disclose that a third party will be fulfilling your order. If you agree to have us share your Personal Information and we do so, your Personal Information will be subject to the privacy practices of that third party. Please note that we are not responsible for the privacy policies and practices of third parties. If you later decide that you no longer wish to receive communications from a third party, you must contact that third party directly.

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   4. Contests, Sweepstakes and Promotions

      We may sponsor contests, sweepstakes or other promotions (any, a Promotion). If you choose to participate in a Promotion, you may be required to provide certain Personal Information. By participating in a Promotion, you agree to the official rules that govern that Promotion. The official rules may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.

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   5. Sharing Between American Greetings' Companies; Business Transitions

      AG Companies are the parents, subsidiaries and affiliates of American Greetings Corporation. We may share your information, including Personal Information, with AG Companies for a variety of purposes, such as to conduct Promotions, offer special premiums, and for business and operational purposes (such as sharing databases and IT equipment). We may, and reserve the right to, share your information with any other company that is not presently, but becomes one of the AG Companies. American Greetings will facilitate payments through third-party partners, but we will not share your credit card information or other payment information with anyone, including AG Companies, without your express, specific permission.

      We may also disclose and transfer your Personal Information: (i) to a subsequent owner, co-owner or operator of a Platform or applicable database; (ii) if an AG Company assigns its rights regarding any of your information to a third party; or (iii) in connection with a corporate merger, consolidation, liquidation, restructuring, the sale of certain of AG Company ownership interests, assets, or both, or other company change, including during the course of any due diligence process (a Business Transition). You acknowledge that a Business Transition may occur, and that any acquirer of an AG Company or its assets may continue to use your Personal Information as set forth in this notice.

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   6. Administrative and Legal Reasons

      We may disclose your information, including Personal Information to third parties (i) if we are required to respond to subpoenas or other legal process or if in our opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation; (iii) to protect and/or defend the Platforms or any of the AG Companies' rights and property, or to enforce the Terms of Service or other policies applicable to the Platforms; or (iv) to respond to an emergency or otherwise protect the personal safety or security of any of the AG Companies or any third party. We may also use Device Identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers, or law enforcement agencies in our discretion. These disclosures may be carried out without notice to you.

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4. THIRD PARTY ANALYTICS AND ADVERTISING SERVICE PROVIDERS; ONLINE TRACKING

   We work with certain third parties (including network advertisers, ad agencies, and analytics companies) for a variety of business purposes. These purposes include providing us with information regarding traffic and use of the Platforms and our advertisements on the Platforms and across the Internet, and to engage in multi-site advertising. For example, if you click on an advertisement that led you to one of our Platforms, our service provider(s) may be able to tell us which advertisement you clicked on and where you were viewing the advertisement; or, you may be served American Greetings' advertisements elsewhere online based on your visit to or use of the Platforms. Some of these third parties may collect Personal Information when you visit the Platforms or other websites or online services. Additionally, we may share certain information derived from your Personal Information with third parties to assist us in delivering content or advertising to you, both on the Platforms and elsewhere online.

   These third parties may set and access their own tracking technologies (including cookies, web beacons, and embedded scripts) and may otherwise collect or have access to your Device Identifier, Usage Data and related information about you. These service providers may use that information for their own purposes, including to target advertisements to you, prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you. We may share the Device Identifier and Usage Data about visitors with third party advertising companies, analytics providers and other vendors for similar purposes.

   American Greetings does not control the information collection, use, or sharing practices of third-party analytics providers or advertisers. Some of these parties may collect your Personal Information when you access the Platforms or other online websites and services.

   While we may use a variety of service providers to perform advertising and analytics services, some of these companies may be members of the Network Advertising Initiative (NAI) or the Digital Advertising Alliance (DAA) Self-Regulatory Program for Online Behavioral Advertising. You can visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the "opt-out" procedures of NAI members. You may also want to visit or http://www.aboutads.info/choices, which provides information regarding targeted advertising and offers an "opt-out" by participating companies in the DAA Self-Regulatory Program.

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5. THIRD PARTY CONTENT AND LINKS TO THIRD PARTIES

   Certain content found on the Platforms may be hosted and served by third parties. The Platforms may also contain links to third party websites or apps that we do not control. This includes links from advertisers, reward programs, sponsors and partners associated with the Platforms. These links may use American Greetings logo or the logo of one of the AG Companies as part of a co-branding agreement (e.g., a third party may be selling or providing American Greetings' products or services). In addition, American Greetings' content may be included on web pages and websites that are not associated with us and over which we have no control.

   These third parties may collect Usage Data through the use of their own cookies, web beacons, or embedded scripts, and they may also independently collect data or solicit Personal Information. American Greetings is not responsible for the privacy practices employed by any third party.

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6. SOCIAL NETWORKING FEATURES; PUBLIC INFORMATION

   1. Community Forums

      The Platforms may provide you the opportunity to participate and post content publicly through interactive features and through other communication functionality (Community Forums). You may choose, through such features or otherwise, to submit or post photographs (which may include metadata), videos, questions, comments, suggestions or other content (collectively, User Content). Please note that certain information, such as your name and other Personal Information, may be publicly displayed on the Platforms along with your User Content.

      Anything you post to a Community Forum is public -- others will have access to your User Content and may use it or share it with third parties. Information or other content you choose to post or make available in the Community Forums may be viewed, collected and used by others. If you choose to voluntarily disclose Personal Information, that information will be considered public information and this Privacy Notice will not apply to such information. If you submit User Content, it may be published online or offline at any time. In addition, we may use your User Content and any excerpt from your User Content in connection with our advertising, marketing, publicity and promotional activities.

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   2. Social Networking Features

      Certain functions on the Platforms may permit interactions between the Platform and a third-party website or interactive service (Social Networking Features). If you choose to use Social Networking Features (e.g., the "like button", "share this card on Facebook"), certain information, which may include your Personal Information, may be publicly displayed, and the third -party website or interactive service used in connection with the Social Networking Features (and its users) may have access to information about you and your use of the Platform.

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   3. Contact Importers

      The Platform may also allow you to import contact information about yourself or third parties from a third-party website or interactive service. For example, the Platform may allow you to provide your login information to your email account so that the Platform may import your contacts or list of persons with whom you have communicated. By providing the login information in your account, you are consenting to American Greetings, or a party on behalf of American Greetings, importing your contacts or list of persons with whom you have communicated for using with the Platform. Unless you consent, we will not store the password you provide if you import your contacts from a third-party source.

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   4. Testimonials

      We may post customer testimonials on our Platforms, which may contain User Content or Personal Information. We will obtain your consent to post your name along with your testimonial via email prior to posting the testimonial on our Platforms. If you wish to request the removal of your testimonial, please contact us at help@americangreetings.com.

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   5. Data Retention

      We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize, hash, or de-identify your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

      Details of retention periods for different types of your Personal Information are available in our Corporate Records Retention Policy, which you can request from us at help@americangreetings.com.

      In some circumstances, you can ask us to delete your Personal Information by following the Request erasure right as outlined in Section VII.

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7. YOUR LEGAL RIGHTS

   Depending on where you reside, you may have the following rights under data protection laws in relation to your Personal Information, including:

   • Request access to your Personal Information (commonly known as a data subject access request). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
   
   
   • Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
   
   
   • Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. If we are not able to comply with your request for erasure for specific legal reasons, we will tell you at the time of your request.
   
   
   • Object to processing of your Personal Information where we are relying on our legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes.
   
   
   • Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following situations: (a) if you want us to establish the data accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
   
   
   • Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
   
   
   • Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

   If you wish to exercise any of the rights set out above, please contact us at help@americangreetings.com.

   You will not have to pay a fee to access your Personal Information (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

   We may need to request specific information from you to help us confirm your identity or the identity of your appointed agent and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to enable us to deal with your request or to speed up our response.

   We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or we have received a number of requests. In this case, we will notify you and keep you updated.

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8. OTHER MATTERS

   1. Privacy Shield Compliance

      American Greetings complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the receipt, collection, use, and retention of Personal Information from EU member countries in reliance on the Privacy Shield. American Greetings has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability of Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Principles, and to view the entities subject to American Greetings' certification, please visit here.

      American Greetings receives Personal Information collected by certain AG Companies and transferred pursuant to the EU-US Privacy Shield Framework for the purposes described in this Privacy Notice. If any such affiliate collects Personal Information under a different privacy policy than this one, American Greetings will comply with the stricter policy.

      • Complaints and inquiries

        In compliance with the EU-US Privacy Shield Principles, American Greetings commits to resolve complaints about its compliance about your privacy and our collection or use of Personal Information. EU individuals with inquiries or complaints regarding this privacy should first contact American Greetings. We will respond to all such inquires and complaints within 45 days of receiving them.

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      • Independent recourse

        American Greetings has further committed to surrender unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus (BBB). If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit http://bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. If neither American Greetings nor the BBB resolves your complaint, you may have the possibility to engage in binding arbitration before a Privacy Shield Panel.

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      • Onward transfer

        American Greetings maintains contracts with third parties that process Personal Information within the scope of the Privacy Shield. The contracts restrict their access, use, and disclosure of Personal Information in compliance with American Greetings' Privacy Shield obligations. American Greetings may be liable for damages if such third parties fail to comply with their contractual obligations.

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      • Federal Trade Commission authority

        American Greetings is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

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      • Required disclosure

        American Greetings may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

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      • Access

        American Greetings acknowledges that EU individuals have the right to access the Personal Information that we maintain about them. Subject to certain exceptions, upon requests and provided you provide us sufficient information to confirm your identity, we will provide you with the Personal Information that we have collected about you for the purpose of enabling you to correct, amend, or delete any inaccuracies. You may make this request by contacting us. If we are not able to provide the information that you are requesting within 30 days of receipt of your request, we will provide you a timeline for providing the requested information. If we deny access to your Personal Information, we will explain why access was denied and give you contact information for further inquiries regarding the denial of access.

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      • Use and choice

        American Greetings will not process Personal Information about EU individuals maintained in reliance on the Privacy Shield for purposes other than those for which the information was originally obtained or subsequently authorized by the EU individual, unless the individual affirmatively and explicitly consents to the processing, or unless an exception applies. Those EU individuals may contact American Greetings at any time to withdraw consent, in which case the person's Personal Information will not be further processed. EU individuals may also contact us to opt out of American Greetings sharing Personal Information with most third parties, excluding those necessary for processing, as required by law, or as necessary to protect the AG Companies and its users.

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   2. Children's Privacy

      The Platforms are not intended for children, and AG Companies do not knowingly collect information from persons younger than the age of sixteen (16). We would ask parents please to ensure that their children under the age of 16 do not provide us with Personal Information without your permission. If we learn that we have inadvertently collected information from a person younger than the age of 16, we will take commercially reasonable efforts to delete that information from our databases.

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   3. Data Security

      We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed. In addition, we classify Personal Information as confidential information and limit access to your Personal Information to those employees, agents, contractors and select third parties who have a business need to know. Processors we appoint will only process your Personal Information on our instructions and they are subject to a contractual duty of confidentiality.

      You should be aware, however, that transmission of information via the Internet is not completely secure. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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   4. Changes to the Privacy Notice; Your Duty to Update Personal Information

      We may change this Privacy Notice at any time without notice to you. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Notice. However, unless you consent, we will not use your Personal Information in a manner materially different than what was stated in our posted Privacy Notice at the time your Personal Information was collected.

      If you have any questions, please contact us through our customer support at help@americangreetings.com or via our Legal Department at legal@americangreetings.com.

      It is important that the Personal Information we hold about you is accurate and current. It is your obligation to inform us if your Personal Information changes during your relationship with us.

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   5. Consent to Transfer

      Please be aware that information we collect through the Platforms may be transferred to and processed in the United States, where the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. For residents or citizens of the European Economic Area (EEA), whenever we transfer your Personal Information, we look to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

      • Transferring your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission.

      • Where we transfer data to AG Companies, and when we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Information the same protection it has in Europe.

      • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to Personal Information shared between the Europe and the US.

      By using the Platforms or providing us with any information, you acknowledge and consent to the transfer, processing, and storage of your information in the United States, or such other countries as American Greetings may choose in its sole discretion.

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   6. California Residents - PRIVACY NOTICE

      We are providing this California Consumer Privacy Act Notice (CCPA Notice) to supplement the information and disclosures already contained in our Privacy Notice. This CCPA Notice applies only to California Consumers visiting American Greetings' Platforms. Any term defined in the CCPA has the same meaning when used in this CCPA Notice. In the event of a conflict between any other American Greetings' policy, statement, or notice and this CCPA Notice, this CCPA Notice will prevail as to California Consumers and their rights under the CCPA.

      1. Right to Know What Personal Information We Collect: We collect information about you as detailed in our Privacy Notice in Section I - INFORMATION COLLECTION. The chart below outlines the categories and illustrative CCPA-examples of Personal Information that American Greetings has collected and/or disclosed, as indicated, for a business purpose in the preceding 12 months.

      Category	Examples	Collected/Disclosed
      A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes/Yes
      B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes/Yes
      C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes/Yes
      D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes/Yes
      E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No/Not Applicable
      F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes/Yes
      G. Geolocation data.	Physical location or movements.	Yes/Yes
      H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes/No
      I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes/No
      J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No/Not Applicable
      K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes/Yes

      2. Right to Know Who We Share Your Personal Information With: As also explained in our Privacy Policy, Section III - HOW AND WHEN WE DISCLOSE INFORMATION TO THIRD PARTIES, we share your Personal Information with the following categories of CCPA-third parties:

         • Affiliates.

         • Vendors and service providers, including for data analytics, payment processing, and marketing and advertising our products and services to you.

         • Third parties integrated into our Platforms.

         • Other third parties for whom we have obtained your permission to disclose your Personal Information.

         For the preceding 12 months, we have disclosed Personal Information in connection with the specific CCPA business and commercial purposes as follows:

         • To create, maintain, customize, and secure your account with us.

         • To provide, support, personalize, and develop our Platforms, products and services.

         • To process your requests, purchases, transactions, and payments and prevent transactional fraud.

         • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses (e.g., recorded customer service calls).

         • To personalize your experience on our Platforms and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Platforms, third-party sites, and via email or text message (with your consent, where required by law).

         • To help maintain the safety, security, and integrity of our Platforms, products and services, databases, and other technology assets, and business.

         • For testing, research, analysis, and product development, including to develop and improve our Platforms, products, and services.

         • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

      3. Right to Request Information: You or your authorized representative have the right to request information about our collection, use, and disclosure of your Personal Information over the past twelve months, including what information we have collected, the purpose behind such collection, what third parties we share such information with, and the business purpose behind such sharing of Personal Information. To request this information, or a copy of your Personal Information, please email us at help@americangreetings.com. You may make this request twice per 12-month period.

      4. Right to Delete Your Personal Information: If you wish for us to delete all or some of your Personal Information, please contact us at help@americangreetings.com.Please take note that some Personal Information (like your email address) is necessary to maintain an account through the Platforms. In addition, we may retain some Personal Information for as long as you have an open, permissioned account with us or as otherwise detailed in Section VI E Data Retention.

      5. Personal Information Sales Opt-Out: You have the right at any time to opt-out of the sale of your Personal Information. You can opt-out by contacting us at help@americangreetings.com. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Information for at least 12 months.

         DO NOT SELL: We do not sell or share your Personal Information in exchange for money; we may disclose, however, certain Internet and electronic network activity (e.g., cookies or tracking tags) information, as a Platform subscriber or user.

      6. Non-Discrimination Rights: We will not discriminate against you for exercising any of your rights under the CCPA. We will not deny you use of our Platform, charge you different prices or rates, or provide you a lower quality of products and services if you exercise your rights under the CCPA. We may, however, offer different tiers of our Platform services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the products or services you receive related to the value of Personal Information that we receive from you.

      Other California Privacy Rights.

      We do not share Personal Information as defined by California Civil Code Section 1798.83 (Shine the Light Law) with third parties for their direct marketing purposes absent obtaining your specific consent. If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: help@americangreetings.com or write to us at the following mailing address: American Greetings Corporation, One American Boulevard, Westlake, OH 44145.

      You must put the statement "Your California Privacy Rights" in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

      If you are a California resident under the age of 18, and a registered user of any Platform, California Business and Professions Code Section 22581 permits you to request and obtain removal of content that you have publicly posted. To make such a request, please send an e-mail with a detailed description of the specific content to help@americangreetings.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information that you have posted and there may be circumstances in which the law does not require or allow removal even if requested.

      Do Not Track Disclosure: The Platforms do not currently respond to Do Not Track signals of web browsers as noted above in Section I (C).

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   7. Nevada Resident Rights

      If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at help@americangreetings.com with the subject line "Nevada Do Not Sell Request" and providing us with your name. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

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9. CONTACTING US; EU REPRESENTATIVE

   If you have any questions, comments, or complaints about your privacy and our collection or processing of your Personal Information, please contact us as follows:

   CUSTOMER SUPPORT

   American Greetings Corporation
   c/o AG Interactive, Inc.
   https://www.americangreetings.com/contact-us
   
   By Phone
   800-711-4474 (between 9am and 5pm Eastern)
   
   Email Us
   help@americangreetings.com
   
   Review our Frequently Asked Question at: https://www.americangreetings.com/faq

   LEGAL SUPPORT

   By Email
   legal@americangreetings.com

   EU REPRESENTATIVE

   American Greetings has appointed its UK subsidiary, UK Greetings, Ltd. (Company Registration Number 3480710, VAT registration number 168966988) as its EU Representative. If you are located in the EU, and have any questions, comments, or complaints relating to our processing of your Personal Information, this Privacy Notice, or our Cookies Policy, please contact us through our EU Representative.

   • By email at GDPR.Enquiry@ukgreetings.co.uk
   • By mail to: Data Protection, UK Greetings Limited, Mill Street East, Dewsbury, West Yorkshire, WF12 9AW
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