Effective: September 1, 2009


PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE YOUR SUBMISSION OF ANY PERSONALLY IDENTIFIABLE INFORMATION.  YOUR VISIT TO OUR WEBSITE IS SUBJECT TO THIS PRIVACY POLICY AND OUR WEBSITE’S TERMS AND CONDITIONS OF USE.

This is the official Privacy Policy for Journal Communications, Inc. (“JCI”, “Company,” “us”, “our”, or “we”), the parent company of the Milwaukee Journal Sentinel Newspaper and various other newspapers and publications, as well as commercial printing service and advertising companies.  JCI is the owner and operator (“Owner and Operator”) of this website (“Site”). This Privacy Policy governs our collection of personally identifiable information (“Personal Information”) both online and offline; it does not govern the Personal Information collected or used by JCI divisions or corporate affiliates (“JCI Affiliates”). 

We hope to provide you with news and information tailored to your individual needs but we also recognize the importance of protecting the privacy of your Personal Information. This Privacy Policy is designed to answer your questions regarding our online and offline information practices and the choices you can make about the way your Personal Information is collected, used and disclosed.  This Privacy Policy is also incorporated in the Site’s Terms andConditions of Use Agreement by reference.

Each time you visit our Site, use our online features and services, or participate in an event or activity offline, you consent to the collection, use, disclosure, processing and management of Personal Information in accordance with this Privacy Policy.  You may withdraw your consent at any time, subject to certain legal or contractual restrictions, reasonable notice, and/or technical restrictions.  If you wish to withdraw your consent, please contact us using the information below.

This Site is also operated in the United States (“U.S.”) and is governed exclusively by U.S. law. If you are not in the U.S., by your submission of any Personal Information to this Site, you are freely consenting to the transfer, collection and use of such Personal Information according to U.S. law.

What are “Your California Privacy Rights”?

Under California law, California residents who have an established business relationship with a business may choose to either opt-out or opt-in to the sharing of their Personal Information to affiliated or non-affiliated third parties for marketing purposes.  Although JCI does not traditionally share Personal Information for marketing purposes with JCI Affiliates (which would be subject to an opt-out consent) or to non-affiliated third parties (which would be subject to opt-in consent), it may do so on occasion or under special circumstances. If you wish to opt-out sharing your Personal Information with JCI Affiliates or to withdraw your opt-in consent to share with non-affiliated entities, please send your written request to us using the e-mail address below and marking your request “Re: Your California Privacy Rights”. Your opt-out request will be processed within ten (10) business days of the date it is received in accordance with the information below.  If you wish to stop all communications from JCI Affiliates, you will need to notify the JCI Affiliate(s) directly.  Please note that non-affiliated third parties are independent from our Company and if you wish to stop all communications from such third parties, you will need to notify the non-affiliated third parties directly.

What types of Personal Information do we collect about you?

We ask you to provide specific types of Personal Information if you wish to receive news and information such as full name, postal address, e-mail address, telephone number and fax number.  We also collect Personal Information offline, such as your full name, company name, postal address, e-mail address, and telephone number.  Where pertinent, we may also collect your Company account number or an employee ID number. We will also collect additional Personal Information if you apply for employment with JCI, such as social security number, date of birth, and other sensitive Personal Information.  It is our policy to not collect sensitive Personal Information via e-mail or online unless such data is reasonably secured. 

How do we actively collect and use Personal Information?

Generally, we actively collect Personal Information from you when you complete online forms or otherwise affirmatively and voluntarily provide such information to us, communicate with us via e-mail; or apply for employment with us.  We may also combine your Personal Information with information obtained from JCI Affiliates, our operational service providers or other companies.  If we share your Personal Information with our advertisers, sponsors and promotional partners (collectively, “Advertisers”), you will be notified in advance and given you prior consent (“opt-in”). 
In addition to corporate transactions and/or matters, your Personal Information will be collected and used for the following features, services and activities: 

Corporate E-mail Alerts and Updates

We collect your e-mail address when you register for various forms of alerts and/or updates about JCI, such as SEC filings, news, events, financial reports, and corporate governance.

Information Request

If you wish to receive information such as Proxy Statements or our Annual Reports, we collect your name, title, organization, investor type, postal address, telephone number (home or work), fax number, and e-mail address.  You will also be required to submit your FedEx account number if you wish to have such information shipped via FedEx.

Investor Earnings Calls

We conduct a quarterly telephone call on the Company’s financial performance and outlook for Wall Street professionals, investors, and other authorized persons (“Earnings Calls”). We may collect a participant’s name, company name, title, and/or contact information.  We will record all Earnings Calls, retain the recording for at least one year, and make the recording and/or a transcript of the recording available to the public via our Site. By participating on an Earnings Call, a person will have affirmatively consented to the recording, retention of their Personal information and voice embodied in the recording, and the recording’s publication/distribution via any medium; participants do not have the right to opt-out to any aspect of an Earnings Call, except to terminate their participation on a call.

Contact Us

If you use our Site’s e-mail address hyperlink or telephone number to contact us, we may ask for your name, company name and title, e-mail address and/or telephone number. We will not ask for, nor should you send any sensitive or confidential Personal Information via e-mail, such as social security number, credit card account number, or a driver’s license number.  If you receive an e-mail requesting any such information from us or someone that claims they are with JCI, please contact our Privacy Administrator immediately.

Employment

We collect Personal Information if you wish to apply offline for a job with JCI.  Such information includes but is not limited to full name, postal address, e-mail address, telephone number, social security number, date of birth, employment history, and personal references. Additional Personal Information may be requested.

Do not send any credit card account or other payment information via e-mail, which is not secured.  We are not responsible for any such Personal Information being transmitted via the Internet.

 

Do we collect Personal Information from or about children?

We recognize the particular importance of protecting the privacy of children.  We are committed to protecting children’s privacy on the Internet and we comply fully with the Children’s Online Privacy Protection Act (COPPA).  We do not generally target children for our goods and services and do not knowingly collect Personal Information from children under the age of 13.  If we discover that a child under the age of 13 has provided Personal Information to us that does not qualify for any regulatory, legal, or security/safety exemption as described below, or we are contacted by a verifiable parent or legal guardian about his or her child’s participation on our Site, we will delete the Personal Information about the child from our active records and from our systems to the extent technically feasible. 

How do we passively collect and use information through tracking technology?

Our Site may passively collect certain kinds of information through various means that reveal the frequency with which you visit our Site, the times and dates of your visits, the pages you reviewed, and other information, including an Internet protocol (IP) address, which is series of numbers that identifies the computer you are using.  We use IP addresses to identify server problems, administer our Site, and compile aggregated statistics for marketing and/or research purposes. We may also use navigational data, including log files and click-stream data, to identify information about your web browser and operating system, and the time period in which you visit our Site or select pages or areas of our Site.  This information is also used to improve our Site’s content and is retained anonymously, meaning that it does not identify an individual user. 

Our Site may also use small text files called “cookies” that are sent to the hard drive of your computer to store bits of information related to your use of our Site.  Cookies can store a variety of information, including IP addresses, navigational data, server information, data transfer times, user preferences, shopping cart information and passwords needed to access our Site.  You may configure your browser to reject cookies.  If you do so, you might not be able to access important functions or enjoy certain conveniences or customized features of our Site.  We may also use “Web beacons” to help personalize your experience, similarly to how we use cookies.  We may also use Web beacons to gather non-Personal Information about the number of users who visit our Site, the areas in which they spend their time visiting, and other demographic data.
We do not ordinarily combine passively collected Personal Information (as described above) with actively collected Personal Information.  We also reserve the right to introduce new passive tracking technologies and techniques. 

Do we share your Personal Information with third parties?

Except as stated in this Privacy Policy or unless your consent is obtained at the time of collection or prior to transfer, your Personal Information will not be shared with any third party outside of JCI Affiliates and our operational service providers.  We will share your Personal Information with JCI Affiliates primarily for business and operational purposes and occasionally for promotional and marketing purposes.  
We also reserve the right to disclose your Personal Information to protect the security of our Site and databases; to protect JCI Affiliates against liability and harm; to respond to subpoenas, judicial processes, or government requests and investigations; to act in respect of an emergency that threatens life, health or security of an individual; to assist in the investigation of a contravention of a law or our Site’s Terms and Conditions for Use; if we believe in good faith that the law requires it or authorizes it; or in connection with any proposed or actual purchase, sale, lease, merger, assignment, re-organization or financing of all or any portion of JCI or any of the business or assets or shares of JCI Affiliates thereof in order for you to continue to receive the same products and services.

We reserve the right to fully use, share, disclose and process any non-Personal Information collected via our Site or offline.

What choices do you have about the collection, use and sharing of your Personal Information?

If you do not want to receive e-mail and other direct marketing communications from us regarding special product offers, sales, promotions, or other information about JCI Affiliates, you may choose to opt-out of receiving such communications from us by clicking on the unsubscribe links in certain e-mail communications from us or by otherwise notifying our Privacy Administrator of your opt-out choice by using our contact information below.

If we plan to share your Personal Information directly with non-affiliated third parties such as Advertisers for purposes of delivering promotional or direct marketing materials directly to you or providing particular online services to you, you will be asked to provide your affirmative consent (“opt-in”) first. If you have opted in to such use of your Personal Information, you may withdraw your consent at any time (“opt-out”), unless there are certain restrictions as stated in this Privacy Policy, Terms of Conditions of Use, Official Rules or are disclosed in advance. For withdrawal of your consent please contact us using our information below and we will take reasonable measures to avoid sharing your Personal Information in the future.  However, please note that non-affiliated third parties are independent from us, and if you wish to stop all communications from such third parties, you will need to address such issues with the third parties directly.

What do you need to know about links to other websites operated by third parties?

Our Site contains a variety of content and functionality and may provide links to other third party websites, including JCI Affiliate websites or the website of a member of our Board of Directors.  Despite these linkages or any references to our business and JCI at those websites, this Privacy Policy applies only to JCI.  This Privacy Policy does not apply to other portions of our internal network or to any external websites.  Please note that you are solely responsible for your interactions with external websites and third parties to which our Site provides you access, such as by clicking on a link. The presence of a link to a third party website does not constitute or imply our endorsement, recommendation, or sponsorship of the third party content, goods, services available through, or contained on, the website or the third party’s business or privacy practices. By use of our Site, you have agreed that you will use the hyperlinks to third party websites at your own risk. 

How can you access, update or delete your Personal Information?

If you wish to change or correct an e-mail address that was submitted for an “Alert” subscription, you must unsubscribe from the Alert service using the unsubscribe link in the e-mail Alert sent to you and then re-subscribe with your correct e-mail address using this Site. If you wish to delete your e-mail address from our Alert database, you must unsubscribe from the service using the unsubscribe link in the e-mail Alert.  If you wish to update or correct any Personal Information you have previously provided to us for “Information Requests” or data to be sent via postal mail, please contact us by using our Privacy Administrator contact information below. You must provide the following information:  your first and last name, your postal address, your immediate contact information (either e-mail address or telephone number) and the type of Information Requests you signed up for. You may also request our Privacy Administrator to remove your Personal Information from our Company records to the extent technically feasible, electronic or otherwise, however, certain records and Personal Information must be retained for tax or regulatory purposes.  (Please submit the above requested Personal Information with your deletion request.) Additionally, our network system may not allow the deletion of all Personal Information.  If we are not able to purge all Personal Information, we will remove such data from an active field or folder.  We will update your Personal Information where appropriate, and we reserve the right to retain Personal Information obtained previously to verify your identity or take other actions that we believe are appropriate.  Personal Information submitted for employment purposes or from participants on our Investor Earnings Calls are not subject to a user’s request for deletion. You may withdraw an application for employment. However, we will retain your application according to Company policies and pursuant to legal requirements.

We also reserve the right to deny access to any user if we believe there is a question about your identity.  And if the burden or expense of providing access to your Personal Information is disproportionate to the risks to your privacy, or if the legitimate rights of others would be violated, we may decide not to provide access to such information.  In such cases, we will provide to you an explanation of why access cannot be provided and a contact person for further inquiries.

What security measures do we take to safeguard your Personal Information?

The security and confidentiality of your Personal Information is important to us.  We maintain reasonable physical, electronic, and managerial procedures to protect your Personal Information.  If we collect sensitive Personal Information such as credit or debit card account numbers, or social security numbers, we will do so using an industry-standard secured transmission process. However, no security measures are impenetrable, and transmissions over the Internet are never 100% secure or error-free.  As a result, we do not, and cannot, guarantee the security of any Personal Information but we will take reasonable measures.

Also, it is your responsibility to safeguard any username or password that you may have received in connection with our Site, and to notify us if you ever suspect that the security and confidentiality of your username or password and associated account has been compromised in any way.  You are solely responsible for any use of our Site via your username and password.

How will you know if we make changes to this Privacy Policy?

We reserve the right to change this Privacy Policy from time to time and in our sole discretion without advance notice to you.  If this Privacy Policy changes, the revised Privacy Policy will be posted at the “Privacy Policy” link on our Site’s home page.  In the event that the change is significant or material, we will notify such a change by revising the link on the home page to read “Privacy Policy - Updated.”  Please check the Privacy Policy frequently and particularly before you submit additional Personal Information via our Site.  If you do not agree to the changes in the Privacy Policy, you understand, acknowledge and agree that your only recourse is to stop using our Site.  Your continued use of our Site constitutes acceptance of such changes in the Privacy Policy, except where further steps are required by applicable law.  The effective date of this Privacy Policy is noted in the beginning of this Privacy Policy.

How can you contact us?

Please feel free to contact us with any comments, questions, or suggestions you may have regarding the Personal Information practices described in this Privacy Policy at PrivacyAdministrator@journalcommunications.com.  Please also contact our Privacy Administrator to report any known or suspected privacy or security breaches.

You may also contact us at:
Journal Communications, Inc.
333 W. State Street
Milwaukee, Wisconsin 53201
Attention: Privacy Administrator