PRIVACY POLICY AND TERMS & CONDITIONS

Last Updated: August 2019

Your privacy is important to us. This Privacy Policy (the "Privacy Policy") governs the use of your Personal Information (as defined below) by Highlights for Children, Inc. and/or its affiliates ("Highlights" or collectively, "we," "us," or "our"). This Privacy Policy explains what information we collect about you, how we use or share such information, how to exercise any rights you may have with respect to your Personal Information, and the safeguards we have in place to reduce the risk of unauthorized access and use.

Table of Contents

1. What does this Privacy Notice cover?
2. What personal information is collected about you?
3. How does Highlights handle children's information?
4. How is your personal information used?
5. How is your personal information shared?
6. How long do we keep your personal information?
7. What choices do you have about processing your personal information?
8. What steps do we take to safeguard your personal information?
9. Product-specific data processing details
10. How to contact us about your personal information and this Privacy Notice
11. CARU's COPPA Safe Harbor Program
12. How will you know if we amend this Privacy Notice?

1. What does this Privacy Notice cover?

This Privacy Policy applies to the following:
• The mobile applications Hidden Pictures Puzzle Town, Highlights Shapes and Highlights Monster Day (collectively, the "Mobile Apps); and
• Any other products, services, interactive features, widgets and resources offered by us and/or our affiliates, distributors or licensees, and all other content included within the Mobile Apps (all of which are collectively referred to as the "Services").

Highlights is a valid licensee, and participating member in good standing, of the Children's Advertising Review Unit's ("CARU") COPPA Safe Harbor Program ("CARU Safe Harbor"). CARU conducts independent audits of our Services and uses other enforcement and accountability mechanisms in its certification process. Services bearing the CARU Safe Harbor icon meet established online information collection, use, and disclosure practices in compliance with applicable privacy laws and best practices.

• DISCLAIMER: Although CARU does not monitor non-U.S. based Services, Highlights takes steps to confirm that non-U.S. based Services follow the applicable data collection guidance and principles of CARU Safe Harbor, including adherence to regulations in the European Union ("EU") and other territories outside of the United States ("U.S.").

2. What personal information is collected about you?

We collect information that you choose to provide us or that we collect from third-parties to provide a service and that personally identifies you. We may ask you to provide us with Personal Information when you register with the Mobile App(s), make a purchase, and at other times. To perform the Services offered, we may need to collect and distribute your Personal Information to our trusted business partners who fulfill the services you request. The decision to provide this information is optional. However, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Mobile Apps or Services or we may not be able to fulfill your purchase.

Information you provide to us

The types of personal information we collect directly from you include parent email address, for those who opt-in to receive emails. The Services do not allow users (including children) to disclose personal information publicly.

Information we collect automatically

We automatically collect non-personal information when you use our Services. For example, we collect install date, device ID, and user state if you opt-into email. We may combine this device and usage information with other personal information.

Cookies and Tracking

We do not use cookies or pixels to track users in our Mobile App(s).
We use email tracking technologies to collect, send and monitor the success of email and push marketing campaigns (for example, recording how many emails in a campaign were opened) for those users who opt-in to receive emails and/or push notifications. In addition to email address, we collect, install date, device ID, and user state in order to send relevant communications. The email collection capability in the app is protected with a parent gate to prevent children from accessing.

Please consult the respective privacy policies and statements of these third parties for more information about how they use your data.

3. How does Highlights handle children's information?

NOTE TO PARENTS

Highlights has developed its Services with the goal of creating a challenging and fun experience for all users. Building on our Privacy Policy, we recognize the need to provide additional privacy protections when children visit the Mobile App(s). Children are defined as under the age of 13 and we do not knowingly collect Personal Information (as defined below in "Information We Collect") from children. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records.

Highlights believes that providing its visitors with accurate and adequate notice about the Services will inform choices and decisions about how to use the Services and will better protect its users' privacy. If you have any questions or comments about this Privacy Policy, please contact us using the contact information provided at the end of this document.

4. How is your personal information used?

Generally

We use Personal Information for internal purposes, such as to:
• Deliver personalized communications, notification, offers and promotions for products and services based on what you've opted-in to receive;

We may store and process personal information in the United States, the United Kingdom, and other countries that may not have the same types of data protection laws as those in your country.

5. How is your personal information shared?

From time to time, we may establish a relationship with other businesses whom we believe are trustworthy and whom we believe have privacy practices that are consistent with ours ("Third-Party Providers"). We do not share your personal information with third parties other than as follows:

• With your consent and only with the information necessary for them to send emails and/or push notifications on our behalf;

• In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets for use in accordance with applicable law. You will have the opportunity to opt out of any such transfer if, in our reasonable judgement, the new entity plans to handle your information in a way that differs materially from this policy; and

• If appropriate to (a) comply with laws or to respond to lawful requests and legal processes, including, for example, to comply with a court order or subpoena; (b) protect the rights and property of Highlights for Children, our agents, our customers, and others, including to enforce our terms, policies, rules, and agreements; (c) protect the safety and security of any person; (d) protect the safety and security of Highlights for Children and our partners' Services, websites, and applications; and/or (e) prevent or stop any illegal unethical, or legally actionable activity, or to comply with law.

Each Third-Party Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use or disclosure. Third-Party Providers are prohibited from using Personal Information other than as specified by us.

Your California Privacy Rights

Since 2005, California Civil Code Section 1798.83 permits to view, correct, or remove certain information provided by you or publicly posted by you, by accessing your Hidden Pictures Digital Play account through hiddenpictures.highlights.com, and editing/removing your information. You will need your password to access your personal account. You may also send us an email asking us to remove your posted information or content at privacyteam@highlights.com. Alternatively, you may write to us at: Highlights for Children, Inc., Attn: Privacy Team, 1800 Watermark Drive, Columbus, Ohio 43215. Please be specific in your request. We will be happy to review, update, or remove your posted information and/or content as appropriate. Residual copies of your posted information and/or content that have been removed from your account may remain in our backup systems for approximately one month. We may still retain your posted information or content to resolve disputes, enforce our agreements with you, or comply with legal requirements; however, we will take steps to limit use of the removed information and/or content to only these purposes.

6. How long do we keep your personal information?

We retain your Personal Information for as long as we have a relationship with you and it is necessary in order to maintain your accounts, provide services, to fulfill your requests, for resolving disputes and for legal compliance and enforcement purposes. We may retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax and/or accounting obligations. We do so in accordance with our data retention policies and applicable law. As a result, copies of content or information previously shared may remain on servers, even after removal requests have been honored.

7. What choices do you have about processing your personal information?

We provide you with various controls over your personal information, for example:

• You may update your information by logging into your Hidden Pictures Digital Play account through hiddenpictures.highlights.com, and editing/removing your information

• If you would like to receive access to your information and/or request the deletion or correction of inaccurate information, you may do so by sending an email to privacyteam@highlights.com or sending a written request to:

Highlights for Children
Attn: Privacy Team
1800 Watermark Drive
Columbus, Ohio 43215
Phone: 614-486-0631

• You can opt out of our promotional emails by clicking "unsubscribe" in the footer of all non-transactional emails.

• You can opt out of push notifications by logging into your App Store or Google Play account and opting out.

• You can choose to block and/or remove all cookies and local storage in your browser settings. You can also opt-out of many third-party analytics and advertising cookies. Please visit http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/ for more information.

Please note that your information may still be shared with certain third parties for transactional purposes such as providing the services you have requested.

"DO NOT TRACK" SIGNALS

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user's activity not be tracked. At this time, our systems do not respond to "do not track" signals.

8. What steps do we take to safeguard your personal information?

We recognize the importance of safeguarding the confidentiality of your Personal Information. Accordingly, we employ reasonable administrative, technical and physical safeguards to protect such personal information from unauthorized access, disclosure and use.

However, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Mobile Apps we cannot and do not guarantee the security of any information you transmit on our Mobile Apps, and you do so at your own risk.

9. Product-specific data processing details

The following are product-specific details to supplement the information in this Privacy Notice.

Please see section 2 and 4 for what we collect and how it's used for Hidden Pictures Puzzle Town, Highlights Shapes and Highlights Monster Day.

10. How to contact us about your personal information and this Privacy Policy

If you have questions or comments about our data practices or this Privacy Policy, you can contact us by emailing us at privacyteam@highlights.com or sending a letter to:

Highlights for Children
Attn: Privacy Team
1800 Watermark Drive
Columbus, Ohio 43215
Phone: 614-486-0631

11. CARU's COPPA Safe Harbor Program

Highlights is a licensee of CARU's COPPA Safe Harbor Program. If you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact CARU at infocaru@bbbnp.org or by mail at CARU, Attn.: COPPA Safe Harbor Program, 112 Madison Avenue, New York, NY 10016 USA.

Please note that CARU is not affiliated with Highlights and cannot help you with non-privacy-related issues.

12. How will you know if we amend this Privacy Notice?

This Privacy Policy is subject to change without prior notice. We may amend this Privacy Policy by changing the last updated date. We encourage you to review this Privacy Policy frequently for any revisions or amendments. If we make material changes to how we collect, use, or share your personal information, we will describe the changes, and, if required by law, seek your consent for such changes.

TERMS AND CONDITIONS

These Terms and Conditions ("Terms") set forth the terms and conditions that govern your use of the application and any delivered content (the "App") as well as your account. To obtain and use this App, you must use your app store account, and comply with the requirements of the app store.

By using the App and accessing the Highlights Consumer Services, Inc. ("Highlights") content, you agree to these Terms and Privacy Policy. We reserve the right to change these Terms and Privacy Policy at any time by making such updated policies available through the App. We may, at any time, modify or discontinue the App or content delivered through the App. We may also, at any time, offer promotional opportunities to only some users of the App.

Intellectual Property

All content distributed by Highlights is the exclusive intellectual property of Highlights and may not be used, copied, reproduced, distributed, transmitted, broadcast, displayed, sold, licensed, or otherwise exploited for any purposes whatsoever, other than through your use of the App for your or your child's or children's personal enjoyment.

Updates and Maintenance

Highlights may, at any time, but is under no obligation to, update the App to provide for different functionality, fix glitches or provide for compatibility with new or updated operating systems. In such event, you may need to download the update to ensure continued use.

DISCLAIMER OF WARRANTIES

HIGHLIGHTS DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, RELATING TO THE DELIVERY AND FUNCTIONALITY OF THE APP AND USE OF THE DELIVERED CONTENT, INCLUDING WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. THE APP IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS. YOU HEREBY AGREE THAT IT IS YOUR SOLE RESPONSIBILITY TO OBTAIN, PAY FOR AND MAINTAIN ANY DEVICES, INTERNET ACCESS, HARDWARE OR SOFTWARE NECESSARY TO OPERATE THE APP.

LIMITATION OF LIABILITY

IN NO EVENT SHALL HIGHLIGHTS' TOTAL AGGREGATE LIABILITY TO YOU ARISING OUT OF THESE TERMS OR YOUR USE OF THE APP EXCEED ANY AMOUNTS THAT YOU HAVE ACTUALLY PAID FOR USE OF THE APP.

Governing Law

These Terms, including the Privacy Policy, shall be governed and construed in accordance with the substantive laws of the State of Ohio, without reference to any conflicts of law provisions. All disputes arising hereunder that cannot be resolved between the parties shall be tried before the State Courts of Ohio or the United States District Courts located in Columbus, Ohio, and their respective appellate courts. Each party hereby irrevocably submits to the jurisdiction and acknowledges the propriety of the venue of such courts, and any final and non-appealable determination reached by such courts.
For questions, please contact us at:

customerservice@highlights.com
Highlights for Children, Inc.
1800 Watermark Drive
Columbus, Ohio 43215 USA