Jonas – Global Website Privacy Policy version 2 Date: 25 January 2021
Tucasi LTD – Privacy Policy
Tucasi Ltd as part of the Jonas
Family of Companies (“Jonas,” “we,” “us,”
”our”) are committed to protecting your privacy. There are various
ways that you might interact with Jonas, and the information you provide when
doing so allows us to improve our services.
This website, our related websites
and any mobile site or mobile application that link to this Privacy Policy)
(collectively, the “Site”, “Sites”) are owned and
operated by Tucasi Ltd with its principal place of business at Wessex House,
Upper Market Street, Eastleigh, SO509FD.
Our privacy policy explains:
·
What information we collect, and
why we collect it;
·
How we use that information;
·
How we protect that information;
·
How you can control your
information, including accessing, updating, and deleting what we store; and
·
How we share information
collected.
This Privacy Policy applies to
Tucasi Ltd and its subsidiaries and affiliates and covers our processing
activities as a data controller.
We do not sell our services to
children and the Site is not intended for or directed at children under the age
of 13 years. As such, our Sites are designed for adult user interaction. We do
not intentionally collect personally identifiable information from children
under the age of 13.
Tucasi are not required to appoint
a formal data protection officer under data protection laws, however, we have
appointed a Data Protection Contact who you can reach out to about any queries
you may have in relation to this Privacy Policy. If you are located in the EEA,
you can contact our representative(s) in the EEA about any data protection
queries, using the contact details below.
Jonas adheres to Canadian and
international statutes and regulations which govern the protection of personal
information. In Canada Jonas adheres to the Personal Information and Protection
of Electronic Documents Act (“PIPEDA”). In the United States, Jonas
adheres to statutes of general application and statutes of specific application
such as the Health Insurance Portability and Accountability Act
(“HIPPA”) where applicable In Australia, Jonas complies with the
Privacy Act, 1988, a federal statute as well as with State and Territory laws
pertaining to protection of personal information, including the Health Records
Act 2001(VIC) where applicable. In New Zealand, Jonas follows the Privacy Act,
1993. In Europe, Jonas adheres to i) until 25 May 2018, EU Directive 95/46/EC,
as transposed into domestic legislation of each Member State; ii) on and from
25 May 2018 the General Data Protection Regulation (EU) 2016/679
("GDPR"); iii) as and when enacted in the United Kingdom, the Data
Protection Act [2018], supplementing and amending the GDPR; iv) EU Directive
2002/58/EC on privacy and electronic communications, as transposed into
domestic legislation of each Member State; and v) any applicable decisions,
guidelines, guidance notes and codes of practice issued from time to time by
courts, supervisory authorities and other applicable government authorities; in
each case together with all laws implementing, replacing or supplementing the
same.
Changes to GDPR post Brexit
On top of the existing
legislation, the UK government has issued a statutory instrument titled
‘The Data Protection, Privacy and Electronic Communications (Amendments
etc) (EU Exit) Regulations 2019’. In simple terms, this amends the
original law and merges it with the requirements of GDPR. The outcome will be a
new data protection framework known as the ‘UK GDPR’.
Once the UK leaves the EU, as a
non-member state it will be reclassified as a ‘third country’.
Under GDPR (the EU version),
transferring personal data from the European Economic Area (EAA) to third
countries is permitted under the following agreement.
The ‘Trade and Cooperation
Agreement’ contains a provision allowing data flows between the EU and UK
to continue as they were pre-Brexit for a maximum of six months. In other
words, data can still be transferred in the way it was pre-January 2021 until
June this year.
Data Transfers from the UK
There are no restrictions or
alterations on sending personal data from the UK to the 27 EU states, 3 EEA
states or the additional 12 countries who were already afforded an adequacy
decision by the EU whilst the UK was still a member. This is because the UK has
carried over the 42 adequacy decisions, so that personal data from the UK can
continue to flow seamlessly.
The ICO will remain the
independent supervisory body regarding the UK’s data protection
legislation.
The UK government will continue to
work towards maintaining close working relationships between the ICO and other
countries’ supervisory authorities once the transition period ends.
Contacting Us
If you have any questions about
our Privacy Policy or your information, or to exercise any of your rights as
described in this Privacy Policy or under data protection laws, you can contact
us as follows:
In the UK
By post:
Data Protection Team, Tucasi Ltd
Wessex House, Upper Market Street, Eastleigh, SO50 9FD
By telephone:
02380 016 564
By email:
support@tucasi.com
Topics
Information we collect
How We Use Information
Marketing
Opting Out
Change of purpose
Tucasi Ltd as data processor
Disclosure of your
personal data to third parties
International transfers
Security of your
personal data
Data retention: How
long we keep your personal data
Your rights
Your right to object
Exercising your rights
Use of Cookies, IP
Addresses and Aggregate Information
Social Media and Online
Engagement
Complaints
Changes to this Policy
Information we collect
Information you give us
We may collect or record basic
personal information which you voluntarily provide through completing forms on
our Site, through electronic mail you send to us, or through other means of
communication between you and us. The categories of personal information you
provide may include:
·
first and last name;
·
job title and company name;
·
email address;
·
phone number
·
mailing address;
·
password to register with us;
·
your personal or professional
interests;
·
any other identifier that permits
us to make contact with you.
We do not generally seek to
collect sensitive personal information (e.g. social security or other
governmental ID numbers, credit card details and account numbers, racial or
ethnic origin, political opinions, religious or philosophical beliefs,
trade-union membership; health or sex life, sexual orientation; genetic or
biometric information) through our Site and if we do we will ask for your
explicit consent to our proposed use of that information at the time of
collection. This information will be collected, stored, accessed, and processed
in a secure manner.
Information we collect from you
We collect, store, and use
information about your visits to the Sites and about your computer, tablet,
mobile or other device through which you access the Sites. This includes the
following information:
·
general non-personal information
pertaining to users of our sites technical information, including the Internet
protocol (IP) address, source domain names, specific web pages, length of time
spent, and pages accessed, browser type, internet service provider, device
identifier, your login information, time zone setting, browser plug-in types
and versions, operating system and platform, and geographical location;
·
information about your visits and
use of the Site, including the full Uniform Resource Locators (URL),
clickstream to, through and from our Site, pages you viewed and searched for,
page response times, length of visits to certain pages, referral source/exit
pages, page interaction information (such as scrolling, clicks and
mouse-overs), and website navigation and search terms used.]
·
information about individual
contacts for our customers (“Business Contact Information”) in the
ordinary course of our business for managing and maintaining customer
relationships. In particular, we may obtain the following types of Business
Contact Information: name, address, invoice information including bank account
information, and order information.
Collection
and Use of Employee Personal Information
We also collect personal
information from our employees and from job applicants (human resource data) in
connection with administration of our 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 our facilities and computer networks, employee profiles,
employee directories, human resource recordkeeping, and other employment
related purposes. It is our policy to keep all past and present employee
information private from disclosure to third parties. There are certain
business related exceptions, and they are:
·
To comply with municipal,
regional, provincial, or federal agency requests;
·
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);
·
Third parties with which we have
contractual agreements to assist in administration of company sponsored
benefits.
Prospective employers, government
agencies, financial institutions, and residential property managers routinely
contact us 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.
How We Use Information
As a data controller, we will only
use your personal information if we have a legal basis for doing so. The
purpose for which we use and process your information and the legal basis on
which we carry out each type of processing is explained in the table below.
Note that we may process your
personal data for more than one lawful ground if the data is used for several
purposes. Please Contact us if you need details about the specific legal ground
we are relying on to process your personal data where more than one ground has
been set out in the table below.
|
Purposes
for which we will process the information |
Type
of data |
Legal
Basis for the processing |
|
To
provide you with information and materials that you request from us. |
(a) Identity |
It
is in our legitimate interests to respond to your queries and provide any
information and materials
requested in order
to generate and develop business. To ensure we offer an
efficient service, we consider this use to be proportionate and will not be
prejudicial or detrimental to you |
|
To
personalise our services and products and the Sites to you. |
(a)
Identity |
It
is in our legitimate interests to improve the Site in order to enhance your
experience on our Site, to facilitate system administration and better our
services. We consider this use to be proportionate and will not be
prejudicial or detrimental to you. |
|
|
(a)
Identity |
It
is in our legitimate interests to market our services and products. We consider
this use to
be proportionate and will
not be prejudicial or detrimental
to you. |
|
To
send you information |
(a)
Identity |
It
is in our legitimate interests to |
|
To
administer our Sites including |
(a)
Identity |
For
all these categories, it is in our |
|
To
measure or understand the |
(a)
Identity |
It
is in our legitimate interests to |
|
To
enforce the terms and conditions and any contracts entered into with you. |
|
It
is in our legitimate interests to enforce our terms and conditions of
service. We consider this use to be necessary for our legitimate interests
and proportionate. |
If you do not wish to provide us with your
personal data and processing such data is necessary for the performance of a
contract with you and to fulfil our contractual obligations to you, we may not
be able to perform our obligations under the contract between us.
Where you
provide consent, you can withdraw your consent at any time and free of charge,
but without affecting the lawfulness of processing based on consent before its
withdrawal. You can update your details or change your privacy preferences by
contacting us as provided in “Contacting us” above.
Where we rely on legitimate interests as a
lawful basis, we will carry out a balancing test to ensure that your interests,
rights, and freedoms do not override our legitimate interests. If you want further
information on the balancing test we have carried out, you can request this
from us by Contacting us.
Marketing
We strive to provide you with
choices regarding certain personal data uses, particularly around marketing and
advertising.
Third-party marketing
We do not share personal data with
any company outside the Jonas group for marketing purposes, however we do
engage data processors to assist in the delivery of emails.
Opting out
You can ask us to stop sending you
marketing messages at any time by clicking the unsubscribe link at the bottom
of emails or email your request to marketing@tucasi.com.
Change of purpose
We will only use your personal
information for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is
compatible with the original purpose. If we need to use your personal
information for an unrelated purpose, we will notify you in a timely manner and
we will explain the legal basis which allows us to do so.
Tucasi Ltd as data processor
In certain cases, we also operate
as a data processor and we collect and process personal information on behalf
of our business customers in the provision of our services and products. In
these circumstances, Tucasi Ltd is acting as a data processor and our business
customers remain the data controller in respect of personal information they
provide to us.
Our business customers remain the
data [information] controllers with respect to any customer information that
they provide to us for our provision of services. To the extent that we are acting
as data processor, we therefore act in accordance with the instructions of such
customers regarding the collection, processing, storage, deletion, and transfer
of customer information, as well as other matters such as the provision of
access to and rectification of customer. We will only use such personal
information for the purposes of providing the services and products for which
our business customers have engaged us.
Our business customers are
responsible for ensuring that these individuals’ privacy is respected,
including communicating to the individuals in their own privacy policies who
their personal information is being shared with and processed by.
As a data processor, we may share
personal information where instructed by our business customer. Where
authorized by the business customer, we may also share personal information
with third party service providers who work for us and who are subject to
security and confidentiality obligations.
Where Tucasi Ltd is acting as a
data processor, we will refer any request from an individual for access to
personal information which we hold about them to our customer. We will not
respond directly to the request.
We will retain personal
information which we process on behalf of our customers for as long as needed
to provide services and products to our customers and in accordance with any
agreement in place with our customers.
Disclosure Of Your Personal Data To Third Parties
We will not sell, rent, lease, or
otherwise share your personal information other than as outlined in this
Privacy Policy or without obtaining your consent beforehand.
Internal third parties
We may share your personal
information with our group companies, affiliates, subsidiaries, or contractors
as necessary to carry out the purposes for which the information was supplied
or collected (i.e. to provide the services and products you have requested from
us).
External third parties
Personal information will also be
shared with our third party service providers and business partners who assist
with the running of the Sites and our services and products including hosting
providers, SMS service providers, Payment Processors, Salesforce (CRM for the
purposes of logging requests/defects), and Act-On (marketing automation). Our
third party service providers and business partners are subject to security and
confidentiality obligations and are only permitted to process your personal
information for specified purposes and in accordance with our instructions.
We may also post links to third
party websites as a service to you. These third party websites are operated by
companies that are outside of our control, and your activities at those third
party websites will be governed by the policies and practices of those third
parties. We encourage you to review the privacy policies of these third parties
before disclosing any information, as we are not responsible for the privacy
policies of those websites.
In addition, we may disclose
information about you when we believe, in good faith, that such use or
disclosure is reasonably necessary to:
·
comply with law
·
enforce or apply the terms of any
of our user agreements
·
protect our rights, property, or
safety,, or the rights, property or safety of our users, or others
·
in the event that we become
involved in a business divestiture, change of control, sale, merger, or
acquisition of all or a part of our business, in which case we may disclose
your personal information to the prospective seller or buyer of such business
or assets;
·
if all or substantially all of our
assets are acquired by a third party, in which case personal information held
by it about its customers will be one of the transferred assets;
·
if we are under a duty to disclose
or share your personal information in order to comply with any legal or
regulatory obligation;
·
if necessary to protect the vital
interests of a person; and
·
to enforce or apply our terms and
conditions or to establish, exercise or defend the rights of Tucasi Ltd, our
staff, customers, or others.
International Transfers
Tucasi do not share your data
outside of the EEA
Security of Your Personal Data
The security of your personal
information is important to us. We follow generally accepted industry standards
to protect the personal information submitted to us, both during transmission
and once we receive it.
We use appropriate measures to
safeguard personally identifiable information, which measures are appropriate
to the type of information maintained and follows applicable laws regarding the
safeguarding of any such information under our control. In addition, in some
areas of our Sites, we may use encryption technology to enhance information
privacy and help prevent loss, misuse, or alteration of the information under
our control. We also employ industry-standard measures and processes for
detecting and responding to
inappropriate attempts to
breach our systems. No method of transmission over
the Internet, or method of electronic storage, can be 100% secure. Therefore,
we cannot guarantee the absolute security of your information. The Internet by
its nature is a public forum, and we encourage you to use caution when
disclosing information online. Often, you are in the best situation to protect
yourself online. You are responsible for protecting your username and password
from third party access, and for selecting passwords that are secure.
If you have any questions about
security on our Site, you can contact us as provided in “Contacting
us” above.
Data Retention: How Long We Keep Your Personal Data
When you contact us, we may keep a
record of your communication to help solve any issues that you might be facing.
Your information may be retained for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirement.
To determine the appropriate
retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised
use or disclosure of your personal data, the purposes for which we process your
personal data and whether we can achieve those purposes through other means,
and the applicable legal requirements.
Details of retention periods for
different aspects of your personal data are available in our retention policy
which is available upon request.
Your rights
Subject to certain limitations,
you have rights under data protection laws in relation to your personal data.
These rights include the rights to:
·
Request access to your personal
data - (commonly known as a “data subject access request”). This
enables you to receive a copy of the personal data we hold about you and to
check that we are lawfully processing it. Note that we may refuse to comply
with a request for access if the request is manifestly unfounded or excessive,
or repetitive in nature.
·
Request correction of your
personal data - this enables you to have any incomplete or inaccurate data we
hold about you corrected, though we may need to verify the accuracy of the new
data you provide to us. Note that we may refuse to comply with a request for
correction if the request is manifestly unfounded or excessive, or repetitive
in nature.
·
Request erasure of your personal
data - this enables you to ask us to delete or remove personal data where there
is no good reason for us continuing to process it. You also have the right to
ask us to delete or remove your personal data where you have successfully
exercised your right to object to processing (see below), where we may have
processed your information unlawfully or where we are required to erase your
personal data to comply with local law. Note that we may refuse a request for
erasure, for example, where the processing is necessary to comply with a legal
obligation or necessary for the establishment, exercise, or defence of legal
claims.
·
Request restriction of processing
your personal data - this enables you to ask us to suspend the processing of
your personal data in the following scenarios: (a) if you want us to establish
the data’s accuracy; (b) where our use of the data is unlawful but you do
not want us to erase it; (c) where you need us to hold the data even if we no
longer require it as you need it to establish, exercise or defend legal claims;
or (d) you have objected to our use of your data but we need to verify whether
we have overriding legitimate grounds to use it. Note that we may refuse to
comply with a request for restriction if the request is manifestly unfounded or
excessive, or repetitive in nature.
·
Request transfer of your personal
data - we will provide to you, or a third party you have chosen, your personal
data in a structured, commonly used, machine-readable format. Note that this
right only applies where your personal data is processed by us with your
consent or for the performance of a contract and when processing is carried out
by automated means.
·
Right to withdraw consent - you
can withdraw your consent at any time where we are relying on consent to
process your personal data. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent.
Your Right To Object
Direct marketing
You have the right to object where
we are processing your personal data for direct marketing purposes. In some
cases, we may demonstrate that we have compelling legitimate grounds to process
your information which override your rights and freedoms.
Where we process your information
based on our legitimate interests.
You also have the right to object,
on grounds relating to your particular situation, at any time to processing of
your personal information which is based on our legitimate interests. Where you
object on this ground, we shall no longer process your personal information
unless we can demonstrate compelling legitimate grounds for the processing
which override your interests, rights, and freedoms or for the establishment, exercise,
or defence of legal claims.
Exercising Your Rights
If you wish to exercise any of the
rights set out above, including withdrawing consent, please contact us giving
us specific details regarding which right you choose to exercise.
No fee usually required
You will not have to pay a fee to
access your personal data (or to exercise any of the other rights). However, we
may charge a reasonable fee if your request is clearly unfounded, repetitive,
or excessive. Alternatively, we may refuse to comply with your request in these
circumstances.
What we may need from you
We may need to request specific
information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person
who has no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all
legitimate requests within one month. Occasionally it may take us longer than a
month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.
Please direct any questions about
your information to the Data Protection Contact identified above.
Use of Cookies, IP Addresses and Aggregate Information
Cookies
In
order to improve the Sites, we may use small files commonly known as
“cookies”. Cookies are a technology that can
be used to help personalize your use of a website. A cookie is a small amount of data which often includes a
unique identifier that is sent to your computer or mobile phone (your
“device”) from the Sites and is stored on your device’s
browser or hard drive. The cookies we use on the Sites won't collect personally
identifiable information about you and we won't disclose information stored in
cookies that we place on your device to third parties.
To enable us to assess the
effectiveness and usefulness of this Site, and to give you the best user
experience, we collect and store information such as pages viewed by you, your
domain names and similar information. Our Site makes use of anonymous cookies
for the purposes of:
·
Completion and support of Site
activity;
·
Site and system administration;
·
Research and development; and
·
Anonymous user analysis, user
profiling, and decision-making.
By
continuing to browse the Sites, you are agreeing to our use of cookies.
If
you don't want us to use cookies when you use the Sites, you can set your browser to notify you when you receive a cookie,
giving you the chance to decide whether to accept it or decline at any time. However, if you block cookies some of the features
on the Sites may not function as a result.
You
can find more information about how to do manage cookies for all the commonly
used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete
cookies which are already stored on your device.
We currently
set the following cookies:
|
Cookie
|
Purpose
|
|
Hazelcast.sessionId
|
[
Required for browsing our website. This is a transient (session) cookie, is
not retained after you have closed your browser, and cannot be used to
identify you ] |
|
JSESSIONID
|
[
Required for browsing our website. This is a transient (session) cookie, is
not retained after you have closed your browser, and cannot be used to
identify you ] |
Cookies from third
parties
We
currently use the following third party cookies:
|
Third Party Cookies |
Cookie Name(s) |
Purpose |
Link |
|
[Google Analytics] |
|
[These cookies provide us with a visitor count and an
understanding of how visitors move around and use the Sites. We can then use
this information to improve navigability and the Sites generally - please see
further details below] |
[Google Privacy
Policy] |
|
[Act-On] |
|
[These cookies enable us to recognise your browser and help us
to track visits to the Sites and also to recognise a return visitor as a
unique user. For example, if you provide us with your name and email address
on the Sites, we will know your identity when you visit the Sites at a later
date.] |
[Act-On Privacy
Policy] |
For
use where Google Analytics used only] [We only use "Google Analytics"
on the Sites. This cookie provides us with a visitor count and an understanding
of how visitors move around and use the Sites. We can then use this information
to improve navigability and the Sites generally. The cookies we use on the
Sites won’t collect personally identifiable information about you and we
won’t disclose information stored in cookies that we place on your device
to third parties.
We
are obliged by Google Analytics to state the following:
The
Sites use Google Analytics, a web analytics service provided by Google Inc.
("Google"). Google Analytics uses "cookies", which are text
files placed on your computer, to help the Sites analyse how users use the
Sites. The information generated by the cookie about your use of the Sites
(including your IP address) will be transmitted to and stored by Google on
servers in the United States. Google will use this information for the purpose
of evaluating your use of the Sites, compiling reports on website activity for
website operators and providing other services relating to website activity and
internet usage. Google may also transfer this information to third parties
where required to do so by law, or where such third parties process the
information on Google's behalf. Google will not associate your IP address with
any other data held by Google. You may refuse the use of cookies by selecting
the appropriate settings on your browser, however, please note that if you do
this you may not be able to use the full functionality of the Sites. By using
the Sites, you consent to the processing of data about you by Google in the
manner and for the purposes set out above.
IP Addresses and Aggregate Information
An Internet Protocol
(“IP”) address is associated with your computer’s connection
to the internet. We may use your IP address to help diagnose problems with our
server, to administer the Site and to maintain contact with you as you navigate
through the Site. Your computer’s IP address also may be used to
provide you with
information based upon
your navigation through
the Site. Aggregate information
is used to measure the visitors’ interest in, and use of, various areas
of the Site and the various programs that we administer. We will rely upon
aggregate information, which is information that does not identify you, such as
statistical and navigational information. With this aggregate information, we
may undertake statistical and other summary analyses of the visitors’
behaviours and characteristics. Although we may share this aggregate
information with third parties, none of this information will allow anyone to
identify you, or to determine anything else personal about you.
Links
The
Sites may, from time to time, contain links to and from the websites of our
business partners, advertisers, and affiliates. If you follow a link to any of
these websites, please note that these websites have their own privacy policies
and do not accept any responsibility or liability for these policies. Please
check these policies before you submit any personal information to these
websites.
Social Media and Online Engagement
We occasionally use a variety of
new technologies and social media options to communicate and interact with
customers, potential customers, employees, and potential employees. These sites
and applications include popular social networking and media sites, open source
software communities and more. To better engage the public in ongoing dialog,
certain of our businesses use certain third-party platforms including, but not
limited to, Facebook, Twitter, and LinkedIn. Third-Party Websites and
Applications (TPWA) are Web-based technologies that are not exclusively
operated or controlled by us. When interacting on those websites, you may
reveal certain personal information to us or to third parties. Other than when
used by our employees for the purpose of responding to a specific message or
request, we will not use, share, or retain your personal information.
·
The Facebook privacy policy is
available at: http://www.facebook.com/policy.php
·
The Twitter privacy policy is
available at: http://twitter.com/privacy
·
The LinkedIn privacy policy is
available at: http://www.linkedin.com/static?key=privacy_policy
Complaints
For the UK:
You have the right to make a complaint at any time with a supervisory
authority, in particular in the EU (or EEA) state where you work, normally live
or where any alleged infringement of data protection laws occurred. The
supervisory authority in the UK is the Information Commissioner who may be
contacted at https://ico.org.uk/concerns/ or telephone: [0303 123 1113].
If we receive formal written complaints, we
will follow up with the person making the complaint. We work with the
appropriate regulatory authorities to resolve any complaints that cannot be
resolved directly. We would, however, appreciate the chance to deal with your
concerns before you approach the ICO so please contact us in the first
instance.
Changes to this Policy
We regularly review our compliance
with our privacy policy. We also adhere to several self-regulatory frameworks
in addition to complying with applicable law.
We may change this privacy policy
from time to time. If this privacy policy changes, the revised privacy policy
will be posted at the “Privacy Policy” link on the Site’s
home page. In the event that the change is significant or material, we will
notify you of such a change by revising the link on the home page to read
“Newly Revised Privacy Policy.” Please check the privacy policy
frequently. Your continued use of the Site constitutes acceptance of such
changes in the privacy policy, except where further steps are required by
applicable law. This privacy policy was last updated on the date set out at the
end of the policy.
LAST
UPDATED: 26 January 2021