Privacy Statement

Last modified: September 1, 2009

At Hardwick-Day we recognize that privacy is important. This Privacy Statement applies to all of the products, services and websites offered by Hardwick-Day, Inc. or its subsidiaries or affiliated companies; collectively, Hardwick Days’ “services.” In addition, where more detailed information is needed to explain our privacy practices, we post supplementary privacy notices to describe how particular services process personal information.

Hardwick-Day generally adheres to the US Department of Commerce’s Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement.

If you have any questions about this Privacy Statement, please feel free to contact us through our website or write to us at:

Privacy Matters
c/o Hardwick-Day, Inc.
8011 34th Ave. South, Ste. 450
Bloomington, MN 55425
USA

Information we collect and how we use it

We offer a number of services that do not require you to register for an account or provide any personal information to us, such as the firm’s Finance & Policy News digest, Enrollment Events Calendar, and HD TV video series. In order to provide our full range of services, we may collect the following types of information:

• Information you provide – When you sign up for a Hardwick-Day Account or promotion that requires registration, we ask you for personal information (such as your name, institutional affiliation, email address and an account password). For certain services, such as our syndicated focus groups, we may also request credit card or other payment account information which we maintain in encrypted form on secure servers.
• Cookies – When you visit http://www.hardwickday.com or an affiliated site, we send one or more cookies – a small file containing a string of characters – to your computer or other device that uniquely identifies your browser. We use cookies to improve the quality of our service, including for storing user data.
• Log information – When you access Hardwick-Day services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
• User communications – When you send email or other communications to Hardwick-Day staff, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
• Links – Hardwick-Day may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our search technology, customized content and advertising. Read more information about links and redirected URLs.
• Other sites – This Privacy Statement applies to Hardwick-Day services only. We do not exercise control over the sites displayed as search results, sites that include Hardwick-Day applications, products or services, or links from within our various services. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

Hardwick-Day only processes personal information for the purposes described in this Privacy Statement and/or the supplementary privacy notices for specific services. In addition to the above, such purposes include:

• Providing our services, including the display of customized content;
• Auditing, research and analysis in order to maintain, protect and improve our services;
• Ensuring the technical functioning of our network;
• Protecting the rights or property of Hardwick-Day or our users; and
• Developing new services.

Hardwick-Day NEVER shares personal information with other companies or individuals outside of Hardwick-Day, except in the following limited circumstances:

• We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
• We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Statement and any other appropriate confidentiality and security measures.
• We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Hardwick-Day, its users or the public as required or permitted by law.

If Hardwick-Day becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice before personal information is transferred and becomes subject to a different privacy statement.

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to Hardwick-Day employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Data integrity

Hardwick-Day processes personal information only for the purposes for which it was collected and in accordance with this Privacy Statement or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services or as otherwise permitted under this Statement. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Enforcement

Hardwick-Day regularly reviews its compliance with this Privacy Statement. Please feel free to direct any questions or concerns regarding this Privacy Statement or Hardwick-Day’s treatment of personal information by contacting us through this web site or by writing to us at:

Privacy Matters
c/o Hardwick-Day, Inc.
8011 34th Ave. South, Ste. 450
Bloomington, MN 55425
USA

When we receive formal written complaints at this address, it is Hardwick-Day’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Hardwick-Day and an individual.

Changes to this Privacy Statement

Please note that this Privacy Statement may change from time to time. We will not reduce your rights under this Privacy Statement without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Privacy Statement changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Statement changes). Each version of this Privacy Statement will be identified at the top of the page by its effective date, and we will also keep prior versions of this Privacy Statement in an archive for your review.