Privacy Policy

Belsito Communications Inc. d/b/a Beaking News Desk

This Privacy Policy (the "Privacy Policy") applies to our website at http://www.breakingnewsdesk.com (the "Website" or "Site") operated by Belsito Communications Inc. d/b/a Beaking News Desk ("Beaking News Desk," "we," "our", or "us"), as well as to the services and information available on the Website (collectively, the "Services"). This Privacy Policy describes how we collect, use, and disclose information, governs how we treat this information, and lets you know your associated rights. Please read this Privacy Policy carefully; once you consent to this Privacy Policy and its terms, it creates legal obligations on you and on us.

Our Website contains links to other websites for your convenience and reference. We are not responsible for the privacy practices or the content of those sites.

PLEASE READ THIS DOCUMENT CAREFULLY BEFORE YOU ACCESS OR USE THE WEBSITE. BY ACCESSING THE WEBSITE, YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS SET FORTH BELOW. IF YOU DO NOT WISH TO BE BOUND BY THESE TERMS AND CONDITIONS, PLEASE DO NOT ACCESS OUR WEBSITE.

To help you navigate our Privacy Policy, we have divided it into numbered sections and provided a set of definitions in Section 19 (Definitions) to allow easy reference to key concepts.

Our Privacy Policy applies to any visitor to the Website (collectively, "you"). We ask you to show your consent to this Privacy Policy in different ways.

2.1 Consent by Site User. We have structured our Website so that you are able to come to our Website and review selected information about our

Services without providing us with any Personally Identifiable Information. By accessing and using our Website or Services as a visitor, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it.

2.2 Consent by User Acting in a Representative Capacity. If you are agreeing to our Privacy Policy on behalf of a company or other legal entity ("Your Organization"), then (i) you represent and warrant that you have authority to act on behalf of, and to bind, Your Organization, and (ii) for all purposes in this Privacy Policy, the term "you" means Your Organization on whose behalf you are acting.

2.3 Right to Withdraw Consent. You have the right to withdraw your consent at any time, in accordance with Section 12 (Your Right to Opt-Out; Object to Processing; Deleting Information).

To provide our Services, and to otherwise conduct our business via the Website, we rely on information provided by, and collected from, our users. This information consists of the following:

3.1 Personally Identifiable Information. We collect certain information that identifies you as an individual (collectively, "Personally Identifiable Information"). The Personally Identifiable Information we collect may include the following:

• Your name;
• Your address (including zip code);
• Your phone number; and
• Your email address

3.2 Non-Personally Identifiable Information. We also collect technical and device-related information that is not Personally Identifiable Information, and instead identifies, or may reasonably be used to identify, a particular user device (collectively, "Non-Personally Identifiable Information"). Non-Personally Identifiable Information is typically collected automatically by technical means and, subject to Section 3.4 (Treatment of Combined Information), for purposes of our Website and Services, consists of the following:

• Device identifiers, such as cookies;
• Device information, such as hardware and software settings;
• IP addresses and log information, such as your device's name, the type and version of your web browser, and referrer addresses that can function to identify a user device; and
• Tracking information that we, or a third party, may collect.

3.3 Anonymous Information. Our Website also collects, processes, and/or uses information that does not identify you or your devices, including Personally Identifiable Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, "Anonymous Information"). Information that meets these criteria might include, for example, demographic information, statistical information (e.g. page views and hit counts), and general tracking information. 3.4 Treatment of Combined Information. If we combine Non-Personally Identifiable Information or Anonymous Information with Personally Identifiable Information, we treat the resulting combination as Personally Identifiable Information.

We collect the above information through the following means and technologies:

4.1 Contacting Us. You can contact us with questions or comments using the form available on our website at https://www.breakingnewsdesk.com/contact or using the information provided in Section 18 (Contact Us). For example, you can contact us to learn more about the content featured on our Website, or to provide us your suggestions. In order to communicate with us, you must provide certain Personally Identifiable Information.

4.2 Information Provided to Third Parties. As explained further in Section 6.1 (Our Service Providers), we may engage third parties to perform certain services for us or on our behalf. The forms on our Website may be managed by such third parties, and we may obtain from the applicable service provider your information that you provide using such forms.

4.3 Newsletters. We may offer newsletters and other content about our services and products, and other issues that we believe may be of interest to you. We will use your Personally Identifiable Information to provide you with this content. You can opt-out of receiving this content, by following the instructions set out in Section 12 (Your Right to Opt-Out; Object to Processing; Deleting Information).

4.4 Device Identifiers; Logs; IP Addresses. To determine whether your device is supported by our Website and Services, we may collect certain information about your device and network, including your IP address, your operating system and browser, your device model, information about your use of the Website or Services, as well as the presence of any software that our Website or Services may require to operate with your device, or other third party software or mobile apps on your device. We automatically receive and record this information in log files, and this is generally Non-Personally Identifiable Information.

4.5 Cookies. A cookie is a small amount of data that is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Website. You may choose not to accept cookies; however, you may need to enable cookies if you wish to access certain personalized features of our Services. Cookies alone are typically Non-Personally Identifiable Information.

4.6 Beacons and Tags. The Website may use certain data collection technologies that rely on: (i) beacons; (ii) pixel tags and object hyperlinking tags; and (iii) other means to link an object to an Internet address, a remote software application, a remote database, or other remote means of receiving or processing information. We may use these technologies to tell us what parts of our Website have been visited or to measure the effectiveness of searches that users perform on our Website. These technologies also enable us to send email messages in a format users can efficiently read, to learn whether these email messages have been opened, and to help ensure, for example, that our messages are of interest to our users. These technologies provide us with Anonymous Information, Non-Personally Identifiable Information and, in certain instances, Personally Identifiable Information.

4.7 Click-Throughs. We may send email messages or display links that use a "click-through URL" linked to our Website or to another resource. When you click one of these URLs, you pass through our web server before arriving at the destination website page or other resource. Click-throughs may use and collect Anonymous Information and Non-Personally Identifiable Information. We may track this click-through data to help determine interest in particular topics and measure the effectiveness of our user communications.

4.8 Other Technologies and Data Sources. We may combine Personally Identifiable Information that you provide to us with other data for purposes of responding to your inquiries, and for other purposes specified in this Privacy Policy. If information we combine in this manner includes your Personally Identifiable Information, we will treat the combined information as your Personally Identifiable Information for all purposes under this Privacy Policy.

4.9 Providing Other Services. We use Personally Identifiable Information to provide the information and services that you request from us or that we make available on our Site. We may use the Personally Identifiable Information that you submit in a manner that we determine to be necessary to provide you with such information and services. For example, you may submit your zip code to us so that we can tailor our Site to provide you with information that is more relevant to locations covered by or near to the provided zip code.

We use the information we collect or process, including Anonymous Information, Non-Personally Identifiable Information, and Personally Identifiable Information, as permitted under Applicable Law, including where the use is based on: (i) the consent you provide to us at the point of collection; (ii) performance of our agreement to provide you with the Services; (iii) compliance with our legal obligations; and/or (iv) our Legitimate Interests, as well as a third party's Legitimate Interests. More specifically, we use the information we collect for some or all of the following:

Note that when determining the bases for our use of your information, we rely on what we consider to be the most appropriate basis, even if there are multiple bases available in connection with our use.

We value your privacy, and we share the information we collect only in the manner set out below.

6.1 Our Service Providers. We engage third parties to perform functions on our behalf, and these may include functions such as maintaining the Website, collecting information, responding to and sending email or other messages, and other functions useful to our business. In this capacity, we may provide service providers with Personally Identifiable Information, Non-Personally Identifiable Information, and Anonymous Information (as applicable). The following are examples:

• We may use service providers to provide customer service (where applicable) or marketing support, such as to process and distribute email. These service providers generally require access to your Personally Identifiable Information in order to perform these services.
• We may use analytics service providers to assist us in understanding and using Non-Personally Identifiable Information and other information that we collect via the Site. A service we may use in this regard is Google Analytics, and information concerning how Google uses the information is available at https://policies.google.com/privacy/partners, and opt-out options specific to Google Analytics are available at https://tools.google.com/dlpage/gaoptout.
• Our Site includes links to third party websites offering services that augment those services offered on our Site.
• We may use service providers to anonymize and aggregate Personally Identifiable Information in order to generate Anonymous Information.
• We may engage service providers to analyze the interests and attributes of our users and, using techniques based on Anonymous Information and Non-Personally Identifiable Information, identify others who might share those interests and attributes. We then use this information to reach out to relevant market segments to provide them information concerning the Website or Services.

We require our service providers to contractually commit to protect the privacy and security of the Personally Identifiable Information they process on our behalf.

6.2 Questions of Harm; Legal Process. We may disclose your Personally Identifiable Information and Non-Personally Identifiable Information to third parties, including law enforcement agencies, attorneys, and private investigators, where it is necessary, or where we have a good faith belief that it is necessary:

• To comply with legal process;
• To protect and defend our rights and property, including the Website and associated content;
• To protect against misuse or unauthorized use of our Website or Services;
• To protect the personal safety or property of Website users or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and
• To cooperate with public and government authorities including, where required, authorities outside your jurisdiction.

While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personally Identifiable Information, then we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted.

6.3 Transfer of the Website. We shall be entitled to transfer information that we collect (including Personally Identifiable Information) to a third party in connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition (including a disposition in connection with a bankruptcy or similar proceedings) of all or substantially all assets or stock of the business unit or division responsible for the information under this Privacy Policy; provided the acquiring third party has agreed to safeguard your Personally Identifiable Information with protections that are compatible with those set out in this Privacy Policy.

6.4 Our Affiliates. We may choose to rely on and share the information we collect with our affiliates. By "affiliate" we mean an entity that is closely related to us, such as an entity that controls, is controlled by, or is under common control with, Belsito Communications Inc. d/b/a Beaking News Desk. Our affiliates will be bound by the terms of this Privacy Policy.

We recognize the sensitivity of our users' Personally Identifiable Information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personally Identifiable Information in accordance with Applicable Law.

We retain Personally Identifiable Information for the period of time necessary to fulfill the purposes for which we obtained the Personally Identifiable Information and consistent with Applicable Law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).

We take reasonable steps (i) to maintain the accuracy of the Personally Identifiable Information we process, and (ii) to limit the Personally Identifiable Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.

Our Site displays online advertising to keep our readers up to speed on various offerings, promotions, and associated content, such as those relating to legal services offered by attorneys and law firms. Our Site may include the use of ad banner partners for the serving and/or targeting of ads, promotions, and other marketing messages. Like many companies, we may also display targeted ads or banners about us to you when you are visiting other websites and apps. The banners and ads that you may see displayed may be based on information we hold about you, such as your previous use of our Website. This may include your search history on our Site, the content you read on our Site, or on banners or ads you have previously clicked on. These ads may be provided, in some cases, by a third-party ad service provider or advertiser (collectively, "Advertisers"). Additionally, Advertisers may place or utilize their own cookies on your browser and may use Anonymous Information about your visit to our Site. If an Advertiser requests that you provide Personally Identifiable Information to it or otherwise accept its cookie on your browser, please be aware that the Advertiser's use and collection of this information and use of any cookies will be governed by its privacy policy or other relevant agreement, and not by our Privacy Policy. We recommend that you review the Advertiser's privacy policy before providing Personally Identifiable Information. In certain circumstances, you may be able opt out of receiving targeted advertising from certain ad networks, data exchanges, marketing analytics, and other service providers as indicated at: http://www.aboutads.info/choices/.

If you would like to review, correct, or update the Personally Identifiable Information that you have provided to us, or if you would like to request an electronic copy of this Personally Identifiable Information for purposes of transmitting it to another company (to the extent Applicable Law provides you with this right to data portability) you may make such requests by us as provided in Section 18 (Contact Us).

12.1 Unsubscribing to Email. If you no longer wish to receive email messages from us, then you can opt out of this Service by either (i) following the "unsubscribe" instructions located near the bottom of each email message, or (ii) contacting us as provided in Section 18 (Contact Us).

12.2 Deleting Information. If you request, we will take reasonable steps to remove your Personally Identifiable Information and Non-Personally Identifiable Information from our databases, within the time frames (if any) set out in Applicable Law. Please understand, however, that if you request the deletion of your information, you will no longer be able to receive certain Services. In addition, it may be impractical (or essentially impossible) to remove the requested information completely, due to requirements promulgated by Applicable Law, and/or data backups, and records of deletions. As such, certain Personally Identifiable Information and Non-Personally Identifiable Information may remain in our databases following the deletion of your account; we will continue to treat the remaining information (if any) in accordance with this Privacy Policy and Applicable Law.

12.3 Objections. If you object to our processing of your Personally Identifiable Information, and a request for us to delete this information is not, in your view, sufficient, please contact us as provided in Section 18 (Contact Us).

12.4 Anonymous Information. We will not delete Anonymous Information from our database, and nothing in this Privacy Policy restricts our use of Anonymous Information.

Under U.S. Federal Law (as reflected in the Children's Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONALLY IDENTIFIABLE INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html.

California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personally Identifiable Information to third parties for direct marketing purposes. The California "Shine the Light" law further requires us to allow California residents to opt out of certain disclosures of Personally Identifiable Information to third parties for their direct marketing purposes.

Our Website does not change its behavior when receiving "Do Not Track" signals from browser software.

We want your feedback. If you have a suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 18 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state's consumer protection authority.

From time to time, we may change this Privacy Policy for our business purposes and to comply with changes in Applicable Law. In the event of any substantive or material changes, we will communicate these changes to you by posting the updated Privacy Policy on the Website and/or notifying you of the change via the Website, email, or other methods. Your continued use of the Website following such notice constitutes your agreement to follow and be bound by the updated Privacy Policy.

If you have any questions about this Privacy Policy, our Website, or Services, please contact us using the information below:

Beaking News Desk

1 Ardmore Street
New Windsor, New York 12553
United States
info@breakingnewsdesk.com

Below are definitions applicable throughout this Privacy Policy. Additional terms are defined in context.

19.1 "Applicable Law" means statutes, regulations, and any other laws that apply to the Website or the Services.

19.2 "Legitimate Interest" means that there is a good reason for processing your Personally Identifiable Information, and that the processing is carried out in a way that minimizes impacts (if any) on your privacy rights and interests. The term "Legitimate interest" also refers to our use of information in ways that you would reasonably expect, based on your relationship to us. For example, there is a Legitimate Interest in collecting and processing your Personally Identifiable Information: (i) to safeguard our Website, Services, networks, content, and related information and resources; (ii) to administer and generally conduct our business; and (iii) to prevent fraud.

The effective date of this Privacy Policy is [May 24, 2019].

© 2020 Belsito Communications, Inc. All rights reserved. No part of this content may be reproduced, stored in any form without written permission from Belsito. Use of the mark Beaking News Desk by Belsito Communications, Inc. is under license from Joseph Belsito.