As of 6-17-2012
Privacy Statement

Your privacy is very important to us. This Privacy Policy discloses how Just Bagels Mfg. Inc. collects, protects, uses and shares personal information gathered about. Our privacy practices are consistent with: The European Union Data Protection Directive and the U.S. Department of Commerce Safe Harbor Program Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement; Fair information practices established by the Organization for Economic Co-operation and Development (OECD); The Asia Pacific Economic Cooperation forum (APEC) Privacy Framework; Applicable country, national, state and local data protection laws (some country’s laws require country specific information in a privacy policy.

All Personal Information is collected in a fair and non-intrusive manner, with your voluntary consent. Personal Information is not accessible to anyone outside the specific function for which it is collected. Just Bagels Mfg. Inc. respects the privacy of our customers, our employees, job applicants, and other visitors to our websites who may choose to provide personal information. We recognize the need for appropriate protections and management of personal information that you provide to us. This Privacy Policy will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared.

Consent
This Privacy Policy applies to all information gathered for and on behalf of Just Bagels Mfg. Inc., whether in writing, verbally or electronically, through any website operated by or on behalf of Just Bagels Mfg. Inc. If you have questions about this Privacy Policy or the protection of your information, please contact our Privacy Officer Charles Contreras at charlii@justbagels.com.

BY SUBMITTING PERSONAL INFORMATION TO JUST BAGELS MFG INC AND/OR BY ACCESSING AND USING THE WEBSITE, YOU AGREE THAT JUST BAGELS MFG INC MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS AS PERMITTED OR REQUIRED BY LAW.
Consent to Share and Disclose Information, Including International Data Transfers
In addition to consenting to this Privacy Policy and the Terms and Conditions, including any relevant supplemental policies, you expressly consent to Just Bagels Mfg. Inc. sharing the information that you have provided, as described herein. Just Bagels Mfg. Inc. may share information with companies that provide support services to it, such as credit card processors, mailing houses, web hosts, technical support providers, fulfillment centers or other service providers or for enforcing or investigating transactions or business operations, because these companies may need information about you in order to perform their functions. These companies are not authorized to use the information Just Bagels Mfg. Inc. shares with them for any other purpose, but Just Bagels Mfg. Inc. does not control these companies. You agree that Just Bagels Mfg. Inc. and those with whom it shares information (the "Recipients") may disclose and transfer your information worldwide, including in and outside the United States, the European Economic Area, Canada, and other jurisdictions serviced by Just Bagels Mfg. Inc.’s distributors, for any purpose relating to Just Bagels Mfg. Inc. operations and programs.

Consent to Electronic Notice if there is a Security Breach
If Just Bagels Mfg. Inc. or a Recipient is required to provide notice of unauthorized access of certain security systems, you agree that Just Bagels Mfg. Inc. or the Recipient, may do so when required or voluntarily by posting notice on the Website or sending notice to any email address Just Bagels Mfg. Inc. or the Recipient has for you, in the good faith discretion of Just Bagels Mfg. Inc. or the Recipient. You agree that notice to you will count as notice to any other individual for whom you are acting and agree to provide the notice to any such individual.

Type of Information We May Collect
Personal Information is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to a Social Security Number and/or Identification Number (hereinafter “SSN/I.N”) or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Personal Information shall include but is not limited to: name, home address, home zip code, home telephone number, mobile phone number, email address, Social Security Number and/or Identification Number, financial information and employment related information such as may be found on resumes, applications, background verification information, or in employment references.
Just Bagels Mfg. Inc. takes measures to maintain the confidentiality of your SSN/I.N to protect your SSN/I.N from unlawful disclosure, and to limit access to your SSN/I.N. Just Bagels Mfg. Inc. will not make your SSN/I.N available to the general public, print your SSN/I.N on any card, require you to provide your SSN/I.N to access any products or services, transmit your SSN/I.N over the Internet unless the connection is secure or your SSN/I.N has been encrypted, or requires the transmittal of your SSN/I.N to access our Website without requiring additional authentication.

Non-personal information is information that is already a matter of public record or knowledge. Business contact information is considered non-personal information and not subjected to special protection and it can be routinely shared with anyone inside or outside of the business. Business contact information shall include but is not limited to: business name, business address, business telephone number, and is not considered personal information in certain jurisdictions.
Sensitive data is information that can include but is not limited to, an individual’s gender, racial or ethnic origins, politics, religion, trade union membership, veteran status, physical or mental health, disabilities, sex life, sexual orientation, or criminal (or alleged criminal) activities, proceedings or convictions. We will never collect Sensitive Personal Information except to comply with Affirmative Action data requirements.
Internet Users - Cookies, Internet Protocol (IP) Address, Aggregate Information
Cookies - in addition to Personal Information, we use data collection devices such as "cookies" on certain web pages to help analyze our web page flow and measure promotional effectiveness. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The “Help” option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you will not have access to many features available on our website.
Web Beacon - Also called a Web bug or a pixel tag or a clear GIF. We use pixels tags or transparent GIF files, to help manage our online advertising and promotions. These tags collect anonymous (not personally identifiable) information about which advertisements and promotions bring users to our website. With both cookie and tag technology, the information that we collect and share is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address. Used in combination with cookies, a Web beacon is an often-transparent graphic image, usually no larger than 1 pixel x 1 pixel, that is placed on a Web site or in an e-mail that is used to monitor the behavior of the user visiting the Web site or sending the e-mail. When the HTML code for the Web beacon points to a site to retrieve the image, at the same time it can pass along information such as the IP address of the computer that retrieved the image, the time the Web beacon was viewed and for how long, the type of browser that retrieved the image and previously set cookie values. Web beacons are typically used by a third-party to monitor the activity of a site. A Web beacon can be detected by viewing the source code of a Web page and looking for any IMG tags that load from a different server than the rest of the site. Turning off the browser's cookies will prevent Web beacons from tracking the user's activity. The Web beacon will still account for an anonymous visit, but the user's unique information will not be recorded.
Children and Data Collection
Just Bagels Mfg. Inc. adheres to the federal privacy protection standards as stated in the Children's Online Privacy Protection Act (“COPPA”). We care about the safety of children. We will not knowingly allow anyone under 13 to provide us any personally identifying information. Children under 13 years of age are required
to obtain the express permission of a parent or guardian before submitting any Personal Information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided us with personally-identifiable information without the consent of a parent or guardian, the parent or guardian of that child should contact the Privacy Officer immediately at charlii@justbagels.com. We will use reasonable efforts to promptly delete the child's information from our servers.

A Note to Parents/Guardians—Additional Information About Children’s Privacy
At Just Bagels Mfg. Inc., children’s privacy is important to us. Therefore, we take additional measures to help children protect their privacy while online including not asking them to disclose more personally identifiable information than is necessary for them to participate in an activity and encouraging them to use non-personally identifiable screen names rather than their real names.
Just Bagels Mfg. Inc. is dedicated to protecting your privacy and handling any personal information we obtain from you with care and respect. This Children's Privacy Statement is designed to answer your questions regarding our privacy policies and principles with respect to children under the age of 13. Just Bagels Mfg. Inc. recognizes the need to provide additional privacy protections when children visit our website at www.justbagels.com.
The Children's Online Privacy Protection Act ("COPPA") requires that we inform parents and legal guardians about how we collect, use, and disclose personal information from children under 13 years of age; and that we obtain the consent of parents and guardians in order for children under 13 years of age to use certain features of our website. Also, when we use the term "parent", we mean to include legal guardians. Children can participate in many of our features without providing personally identifiable information. However, to enable their participation in certain of our interactive features, we may ask children to provide us with personally identifiable information. The types of information we may request include first name as well as the child’s and parent’s email addresses. We use a child’s email address to respond to a specific request to participate in an activity (e.g., participate in a contest or sweepstakes, respond to their question, or enable them to subscribe to a newsletter). We use parents’ e-mail addresses to obtain their consent or notify them of their child's online activities and enable the parent to unsubscribe the child from a newsletter or other similar activity. We do not share children's personally identifiable information with outside third parties not bound by this Privacy Policy. Sometimes, we use agents or contractors to help us conduct a contest or sweepstakes, send prizes to winners, or provide customer service related to activities on the site. In these cases, we require the agent or contractor to keep the information confidential and to use it only for the specific services they are performing. At any time parents can refuse to permit us to collect further personal information from their child and can request that any personal information we have collected be deleted from our records. We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, and/or share their child’s personal information. Please note that, at all times, parents should update their personal information to provide us a current email address.
Our Use of Your Personal Information
We use your Personal Information to facilitate the services you request. We have tailored our Privacy Policy to adequately advise of the use of your Personal Information.

Testimonials If you submit or post a testimonial comment, review, suggestion or any work of authorship (collectively a “Submission”) to us, including without limitation, Submissions about our products or services, such Submission will not be confidential or secret, and may be used by us in any manner. By submitting or sending a Submission to us, you (i) represent and warrant that the Submission is original to you, that no other party has any rights thereto, and that any “moral rights” in such Submission have been waived, and (ii) you grant us a royalty-free, unrestricted, worldwide, perpetual, irrevocable, non-exclusive and fully transferable, assignable and sublicensable right and license to use, reproduce, publish, distribute, translate, summarize, modify and adapt such Submission (in whole or in part) and/or to incorporate in other works in any form, media, or technology now known or later developed, in our sole discretion, with or without your name.

Collection and Use of Employee Personal Information

Just Bagels Mfg. Inc. also collects Personal Information from its employees and applicants (human resource data) in connection with administration of its Human Resources programs and functions. These programs and functions include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to Just Bagels Mfg. Inc. facilities and computer networks, employee profiles, internal intranet employee directories, Human Resource recordkeeping, Affirmative Action data, and other employment related purposes. It is the policy of Just Bagels Mfg. Inc. to keep all past and present employee information private from disclosure to third parties. There are certain business related exceptions and they are:
1. To comply with county, state or federal agency requests; 2. Inquiries from third parties with a signed authorization from the employee to release the information, except in situations where limited verbal verifications are acceptable (see below);
3. Third parties with which Just Bagels Mfg. Inc. has contractual agreements to assist in administration of company sponsored benefits.
Verifications of Employment
Prospective employers, financial institutions, and residential property managers routinely contact Just Bagels Mfg. Inc. requesting information on a former or current employee's work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the Human Resources Department or Payroll Department. For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee's signed authorization to release information. The form will be returned directly to the requesting party and filed as part of the Human Resources or Payroll Department’s confidential records.
Medical Information
Just Bagels Mfg. Inc. is compliant with federal HIPAA regulations and only utilizes information related to the company sponsored healthcare plan on a "need to know" basis for administration of the healthcare plan.

Collection and Use of Customer Information
Just Bagels Mfg. Inc. will not collect customer Personal Information, unless the customer contacts Just Bagels Mfg. Inc. directly. We may share Personal Information with our service providers, consultants and affiliates for our internal business purposes. Except as described in this Privacy Policy, Just Bagels Mfg. Inc. will not share Personal Information with a third party, unless a customer requests, consents to such disclosure, or disclosure is required or authorized by law. Just Bagels Mfg. Inc. reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena, or court order legally requires or authorizes us to do so.

Security
We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.
We safeguard your Personal Information on the Internet by using industry-standard practices. Although "guaranteed security" does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Policy and all applicable laws and regulations. We maintain physical, electronic and procedural safeguards as appropriate to safeguard your Personal Information.
Phishing
Identity theft and the practice currently known as “phishing” are of great concern to Just Bagels Mfg. Inc.. Accordingly, safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, Social Security Number or National Identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Storage, Retention and Accuracy of Personal Information Just Bagels Mfg. Inc. insures that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information. Just Bagels Mfg. Inc. will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and your consent to such purpose remains valid after termination of our relationship with you.
We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

Access, Control and Update Information About You
We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. Therefore, whenever you believe that your Personal Information needs to be updated, you can email us at charlii@justbagels.com to update your contact information. To protect your privacy, we will take reasonable steps to help verify your identity before granting access or making changes.
Contact Information
You may contact us to access, correct or delete your Personal Information. If necessary, we will contact another individual to assist in completing your requested task. We want to be sure that we keep only the most accurate and up-to-date Personal Information in our records. If you have any questions or complaints, please contact Charles Contreras. Mr. Contreras can be reached by telephone at: (718) 328-9700; by Facsimile at: (718) 328-9997; by email at: charlii@justbagels.com; or by mail at Just Bagels Mfg. Inc., 527 Casanova Street, Bronx, NY 10474

Your California Privacy Rights
Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please email the Privacy Officer at charlii@justbagels.com or write to us at: Just Bagels Mfg. Inc., 527 Casanova Street, Bronx, NY 10474
Attention: California Disclosure Information. We will respond to such written requests within 30 days following receipt at the mailing address above. We reserve the right not to respond to requests submitted other than to the address specified above or otherwise exempted by law. Please note that we are required only to respond to each customer once per calendar year.
Safe Harbor Compliance
Just Bagels Mfg. Inc. is in compliance with the U.S. Department of Commerce Safe Harbor requirements regarding the transfer of personal information from the European Economic Area (“EEA”) or Switzerland to the United States. The principles of Safe Harbor compliance are:
Notice - Individuals must be informed that their data is being collected and about how it will be used;
Choice - Individuals must have the ability to opt out of the collection and forward transfer of the data to third parties;
Security - Reasonable efforts must be made to prevent loss of collected information;
Data Integrity - Data must be relevant and reliable for the purpose for which it was collected;
Access - Individuals must be able to access information held about them, and correct or delete it if it is inaccurate;
Enforcement - There must be effective means of enforcing these rules.

Further information regarding the Safe Harbor principles and certification process can be found at
www.export.gov/safeharbor. In addition, the U.S. Department of Commerce maintains a list of all compliant organizations, which can be accessed at http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list.

Members of the European Union

If you are a resident of the European Economic Area (“EEA”) or Switzerland and have any concerns or complaints, please first address these issues to the Privacy Officer. Just Bagels Mfg. Inc is located in the United States, as are the servers that make their site available. All matters relating to privacy issues and this website are governed by the laws of the United States and the State of New York. If the Privacy Officer does not satisfactorily address a complaint within thirty (30) days, any dispute, controversy or claim shall be settled by an arbitration administered by an arbitration agency, such as the American Arbitration Association (“AAA”). All arbitrations will be conducted in English. Judgment rendered by the arbitrator may be entered in any court having jurisdiction. The costs of the arbitration will be borne equally by the parties. Connecticut, U.S.A. shall be the site of all hearings, and such hearings shall be before a single arbitrator. You may also submit complaints to the Federal Trade Commission at http://www.ftc.gov/ftc/complaint.htm or via phone at (202) 382-4357.

Changes to our Privacy Policy
Just Bagels Mfg. Inc will update this Privacy Policy occasionally. When Just Bagels Mfg. Inc posts changes to this Privacy Policy, we will also revise the "Last Updated" date below on Just Bagels Mfg. Inc’s Privacy Policy. If there are material changes to this Privacy Policy, FWH will notify you by email, or by means of a notice on our home page. Just Bagels Mfg. Inc. encourages you to review this Privacy Policy periodically to be informed of how Just Bagels Mfg. Inc. is protecting your information and to be aware of any changes to the Privacy Policy. Your continued use of the site after the posting of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. This Privacy Policy is incorporated into any Terms and Conditions governing the various websites and any programs or services operated or managed on or behalf of Just Bagels Mfg. Inc. Any changes to this Privacy Policy are effective immediately after being posted by Just Bagels Mfg. Inc.

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