Weight Watchers Safe Harbor Privacy Statement

WEIGHT WATCHERS INTERNATIONAL
SAFE HARBOR PRIVACY STATEMENT

Weight Watchers International, Inc. and its US subsidiary WeightWatchers.com, Inc. (collectively, “Weight Watchers”, “we”, “us” or “our”) adhere to the Safe Harbor privacy principles and frequently asked questions published by the United States Department of Commerce (“Safe Harbor Principles”), regarding the collection, storage, transfer, use and other processing of personal data about individuals collected in the European Economic Area ("EEA") and Switzerland and transferred to the United States.

Scope

This Safe Harbor Privacy Statement (“Statement”) outlines our general policy and practices for implementing the Safe Harbor Principles for online and offline Personal Information (as defined below) collected in the EEA and Switzerland from consumers and employees in support of Weight Watchers commercial operations and human resources, respectively, and transferred to the United States. We limit the collection of Personal Information to what we need to know in order to support these operations. For example, we may use Personal Information provided by consumers to communicate with them about our products and services. We may use Personal Information about Weight Watchers personnel for the purpose of human resources administration and recruitment. For purposes of this Statement, “Personal Information” includes information that identifies an individual or can be used to identify or contact an individual. It does not include information that by itself cannot be used to identify or contact an individual, such as demographic information (like age, profession or gender) or data that is reported in the aggregate.

For more information about Safe Harbor or to access Weight Watchers certification statement, go to http://www.export.gov/safeharbor/.

Privacy Principles
Notice

Weight Watchers notifies individuals located in the EEA and Switzerland about the purposes for which we collect and use Personal Information about them, the types of third parties to which we disclose the information, the choices individuals have for limiting the use and disclosure of their information, and how to contact us about our practices concerning Personal Information. We provide such notice through this Statement, in our web pages and/or in other locations where we collect information.

Choice

We do not use Personal Information for purposes incompatible with the purposes for which the information was originally collected without notifying the relevant individuals of such uses and offering an opportunity to opt out of such uses (or, in the case of sensitive personal information, as defined in the Safe Harbor Principles, without explicit consent of the individual).

Onward Transfer of Personal Information

Weight Watchers may share Personal Information with independent contractors and third party vendors and suppliers we have retained to perform specific services or provide specific products on our behalf (“Agents”). We require these Agents to whom we disclose Personal Information and who are not subject to laws based on the European Union Data Protection Directive to either (i) subscribe to the Safe Harbor Principles or (ii) or contractually agree to provide at least the same level of protection for Personal Information as is required by the relevant Safe Harbor Principles. Where Weight Watchers has knowledge that an Agent is using or sharing Personal Information in a way that is contrary to these principles, we will take reasonable steps to prevent or stop such processing.

In addition, we may disclose Personal Information (i) among Weight Watchers subsidiaries and affiliates, (ii) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process, (iii) in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our company policies or website agreements, or to protect the safety and/or security of our users, our website or the general public, (iv) in the event of a sale, merger or other transfer of all or substantially all of the assets of Weight Watchers, or (v) where individuals have given their permission to make such disclosure.

Data Integrity

Weight Watchers takes reasonable steps to ensure that Personal Information we collect is relevant for the purposes for which it is to be used and that the information is reliable for its intended use and is accurate, complete and current. We depend on individuals to update or correct Personal Information whenever necessary.

Access to Personal Information

Weight Watchers provides individuals with reasonable access to the Personal Information maintained about them. We also provide a reasonable opportunity to correct, amend or delete that information where it is inaccurate. We may limit or deny access to Personal Information where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Safe Harbor Principles. To obtain access to Personal Information, individuals may contact Weight Watchers as specified in the "How to Contact Us" section of this Statement.

Security

Weight Watchers maintains reasonable administrative, technical and physical safeguards to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement and Dispute Resolution

Weight Watchers has established procedures for reviewing and verifying our ongoing compliance with this Statement, including an annual self-assessment of our practices.

Individuals with questions or concerns about this Statement should first contact our Privacy Coordinator at the address set out below in the “How to Contact Us” section. If the inquiry is not satisfactorily addressed or resolved through our internal processes, then individuals may take advantage of the dispute resolution process:

Weight Watchers has agreed to cooperate with the European Data Protection Authorities for the purpose of handling any unresolved complaints regarding Personal Information of Weight Watchers employees collected in support of our human resources operations.
For inquiries involving other types of data, please contact the TRUSTe Safe Harbor Dispute Resolution Program at http://www.truste.org/consumers/watchdog_complaint.php or by postal mail at Watchdog Complaints, TRUSTe, 55 Second Street, 2d Floor, San Francisco, CA, USA 94105, by phone at (415) 520-3400 or by fax at (415) 520-3420. TRUSTe will act as a liaison to Weight Watchers to resolve your inquiries.

How to Contact Us

For any questions or concerns about this Statement or our privacy practices, please contact our Privacy Coordinator in any of the following ways:

Email our Privacy Coordinator at:
privacy@weightwatchers.com

Or, write to our Privacy Coordinator at:
Weight Watchers International, Inc.
675 Sixth Avenue, 6th Floor
New York, NY 10010
Attn: Privacy Coordinator

Or, fax our Privacy Coordinator at:
(212) 589-2601

Changes to this Safe Harbor Privacy Statement

This Statement may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. If we decide to change this Statement, we will post those changes on our website at www.weightwatchers.com.

Last updated: July 29, 2013