Sports Debatable understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of our members and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. DEFINITIONS AND INTERPRETATION
In this Policy the following terms shall have the following meanings:
Account – means an account required to access and/or use certain areas and features of Sports Debatable
Cookie – means a small text file placed on your computer or device by Sports Debatable when you visit certain parts of Sports Debatable and/or when you use certain features of Sports Debatable. Details of the Cookies used by Sports Debatable are set out in Part 14, below; and
Cookie Law – means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
2. INFORMATION ABOUT US
Sports Debatable is owned and operated by Sports Debatable LLC
Registered address: 24 Providence Rd, Morton PA 19070
Email address: firstname.lastname@example.org
3. WHAT DOES THIS POLICY COVER?
4. WHAT IS PERSONAL DATA?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. WHAT ARE MY RIGHTS?
Under the GDPR, you have the following rights, which we will always work to uphold:
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. [we do not use your personal data in this way.]
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
6. WHAT DATA DO WE COLLECT?
• Date of birth;
• Email address;
• Telephone number;
• Information about your sports interests;
• IP address;
• Web browser type and version;
• Operating system;
A list of URLs starting with a referring site, your activity on Sports Debatable, and the site you exit to;
Information our servers automatically collect when you access the Application, such as your native actions that are integral to the Application, including posting, reacting, or replying to a post, as well as other interactions with the Application and other users via server log files.
The Application may by default access your Facebook basic account information, including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. For more information regarding Facebook permissions, refer to the Facebook Permissions Reference page.
Data from Social Networks
User information from social networking sites, such as including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks. This information may also include the contact information of anyone you invite to use and/or join the Application.
We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data
Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.
We may request to send you push notifications regarding your account or the Application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
7. HOW DO YOU USE MY PERSONAL DATA?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
Providing and managing your Account;
Providing and managing your access to Sports Debatable;
Personalizing and tailoring your experience on Sports Debatable;
Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email, SMS or Push Notification that you have opted-in to (you may unsubscribe or opt-out at any time.
Analyzing your use of Sports Debatable and gathering feedback to enable us to continually improve Sports Debatable and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. we will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on Sports Debatable may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
8. HOW LONG WILL YOU KEEP MY PERSONAL DATA?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
9. HOW AND WHERE DO YOU STORE OR TRANSFER MY PERSONAL DATA?
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
We ensure that all password information is encrypted using SHA-256 level encryption.
The entire Sports Debatable application uses SSL to ensure that data is captured and stored securely.
We use SSH key pair authentication to ensure that only specific staff machines can access our database.
Any device without the correct SSH key that tries to access our database will be rejected and the sending IP address is blocked.
10. DO YOU SHARE MY PERSONAL DATA?
We may share your personal data with other companies in our group for legitimate business purposes. This includes subsidiaries.
We may sometimes contract with the following third parties to supply certain products or services. These may include payment processing, ad delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
Google – Ad delivery and analytics
Flurry- App analytics
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the GDPR, as explained above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. HOW CAN I CONTROL MY PERSONAL DATA?
In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Sports Debatable, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails.
12. CAN I WITHHOLD INFORMATION?
You may access certain areas of Sports Debatable without providing any personal data at all. However, to use all features and functions available on Sports Debatable you may be required to submit or allow for the collection of certain data.
13. HOW CAN I ACCESS MY PERSONAL DATA?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. [To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.]
We will respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Sports Debatable you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Sports Debatable for personalizing your experience including the advertisements that you may see.
What is a cookie?
A cookie is a small file of letters and numbers that are placed on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive.
How are cookies used on Sports Debatable?
Cookies perform important and useful functions:
• they make it possible to provide personalized pages for visitors;
• they help advertisers avoid repeatedly serving the same ads to the same visitor;
• they help website owners determine which sections of their sites are more appealing;
What is device identification?
Device Identification is a technology that identifies devices by collecting information from the browser on the device, such as the browser version, operating system, IP address, installed fonts, time zone and more. These pieces of information are used to uniquely identify a device. This process does not use any personal information. The device ID generated through the device identification process may be stored in a cookie.
What are the different types of cookies?
First-party cookies are those set by Sports Debatable to improve your user experience. They enable us to log you in automatically if you have set your login status to ‘remember me’. They also enable us to provide you with personalized information and ensure that we only show you information that is relevant to members in your country.
Third-party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website this would be a third-party cookie.
NOTE: None of our third party cookies disclose any personal information about a user. The statistics are collected anonymously.
How to delete and block our cookies?
Can I withdraw my consent?
If you do not wish to have Sports Debatable cookies stored on your machine, you will need to delete your cookies using your internet browser settings.
15. CHILDREN’S POLICY
We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below
By using the Sports Debatable app, you signify your acceptance of these privacy policies. If you do not agree to this policy, please do not use our Site or App. Your continued use of the Site or App following the posting of changes to this policy will be deemed your acceptance of those changes.
17. HOW DO I CONTACT YOU?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: email@example.com
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
What personal information do we collect from the people that visit our blog, website or app?
When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience.
WHEN DO WE COLLECT INFORMATION?
We collect information from you when you register on our site, subscribe to a newsletter, fill out a form or enter information on our site.
HOW DO WE USE YOUR INFORMATION?
We may use the information we collect from you when you register, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:
- To administer a contest, promotion, survey or other site feature.
- To send periodic emails regarding your order or other products and services.
HOW DO WE PROTECT VISITOR INFORMATION?
We do not use vulnerability scanning and/or scanning to PCI standards.
We only provide articles and information. We never ask for personal or private information like names, email addresses or credit card numbers.
We do not use an SSL certificate?
- We do not need an SSL because:
We do not collect credit card information
DO WE USE ‘COOKIES’?
- Keep track of advertisements.
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If you disable cookies off, some features will be disabled It won’t affect the user’s experience that make your site experience more efficient and some of our services will not function properly.
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information.
We do not include or offer third-party products or services on our website.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We use Google AdSense Advertising on our website.
We have implemented the following:
- Remarketing with Google AdSense
- Google Display Network Impression Reporting
- Demographics and Interests Reporting
We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT
According to CalOPPA we agree to the following:
Users can visit our site anonymously.
- Via Email
Users are able to change their personal information:
- By emailing us
How does our site handle do not track signals?
We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third-party behavioral tracking?
It’s also important to note that we do not allow third-party behavioral tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under 13.
FAIR INFORMATION PRACTICES
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email
- Within 7 business days
We also agree to the Individual Redress Principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM ACT
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions.
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM we agree to the following:
- NOT use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
The General Data Protection Regulation (GDPR) replaced the requirements of the Data Protection Act (DPA) 1998 in May 2018. The General Data Protection Regulation (GDPR) includes rules on giving privacy information to data subjects in Articles 12, 13 and 14. These are more detailed and specific than in the DPA and place an emphasis on making privacy notices understandable and accessible.
- Privacy Notice
This Privacy Notice sets out how we may use, process and store your personal identifiable information (PII). We may get that information from you or our partners, through contracts or other legal arrangements you have with us or our partners on behalf of us, in order to deliver contractual/legal obligations. In other cases, we will get that information from you with your permission and consent, or we may receive your personal information from third parties who you have given consent to pass this information on to us.
Sports Debatable LLC may collect information from you because we have a legal reason (allowed by law or under contract) to collect the information, or because you have consented for us to do so for a specific purpose.
- Information Provided
You may give us information about you with your consent, for example:
Through Contractual agreements
By filling in a form or sending us an e-mail
This information may be personal, financial, business or related to your contractual history with us. You may give us information for legal reasons, such as to enter into a contract with us, when you are buying goods or services from us, or when you are considering these options.
Information we collect about you
If you visit our website, we may automatically collect information about you, for example:
Information about what type of device you use to connect to our website
How you interact with our
Information we receive from other sources
We may receive information about you if you use any of the other websites we operate, any other services we provide, or from our business partners instructed to collect information on our behalf.We also work with third parties, including, for example, business partners, sub-contractors in technical, payment and may receive information about you from them as part of the service we provide you, or for legal reasons.
- How We Use Information We Collect
We never sell personal information
We will never sell your Personal Information to any third party.
Use of personal information
Personal Information to the third party. In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. If you do not want us to share your personal information with these companies, contact us at firstname.lastname@example.org
We use the information collected through our Subscription Service by our customers for the following purposes: (a) to provide the Subscription Service (which may include the detection, prevention and resolution of security and technical issues); (b) to respond to customer support requests; and (c) otherwise to fulfil the obligations under the Sports Debatable LLC Customer Terms of Service.
Use of navigational information
We use Navigational Information to operate and improve the Websites and the Service Portal. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Sports Debatable LLC.
Customer testimonials and comments
We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer’s consent prior to posting the customer’s name and testimonial.
Use of credit card information
If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
Security of your personal information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When sensitive Personal Information (such as a credit card number and/or geo-location data) is collected on our Websites and/or transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
Social media features
Retention of personal information
We retain personal information that you provide us as long as we consider it potentially useful in contacting you about our services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements, and then we securely delete the information. We will delete this information from the servers at an earlier date if you so request.
We reserve the right to use or disclose your personal information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
- Navigational Information
We use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web server. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a Web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize pages on our Websites, cookie helps us to recall your specific information on subsequent visits. When you return to the same Website, the information you previously provided can be retrieved, so you can easily use the customized features.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Sports Debatable LLC Website you visit. Sports Debatable LLC keeps track of the Websites and pages you visit within Sports Debatable LLC, in order to determine what portion of the Sports Debatable LLC Website is the most popular or most used. This data is used to deliver customized content and promotions within the Sports Debatable LLC Website to customers whose behavior indicates that they are interested in a particular subject area.
We may collect demographic information, such as your post code, age, gender, preferences, interests and favorites using log files that are not associated with your name or other personal information.There is also information about your computer hardware and software that is automatically collected by us. This information can include: your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Sports Debatable LLC to maintain the quality of the Subscription Service, and to provide general statistics regarding use of the Sports Debatable LLC Website. For these purposes, we do link this automatically-collected data to Personal Information such as name, email address, address, and phone number.
Why does Sports Debatable LLC collect Personal Identifiable Information (PII)?
Sports Debatable LLC collects PII for the some or all of following reasons:
To provide services and support to you after you have entered into a contract
To provide information about products or services you have shown interest in, if you are already an existing Sports Debatable LLC customer
To provide information to you about products or services you have purchased from us, or related products or services
To provide goods or services to you under contract
For legal reasons, for example, if you have entered into a contract with us
To provide information to you about our products and services if you have consented to receive
What legal basis does Sports Debatable LLC have for processing PII?
Sports Debatable LLC may process your information because:
We have a contract with you
You have given us permission to do so
We must provide services to you after you have purchased something from us
To comply with the
Who might Sports Debatable LLC share PII information with?
Sports Debatable LLC may share your personal information with third parties, either because you have consented to allow us to do so or for legal reasons. For example, we may share your personal information with:
Sub-contractors and third parties for the purpose of providing or continuing to provide the products and services we are contracted to
With third parties because you have given consent
Sports Debatable LLC must comply with a legal obligation
To protect the rights, property, or safety of Sports Debatable LLC, our customers or others
We will exchange information with other companies or organizations to prevent fraud or to reduce our credit risks
Sports Debatable LLC may, from time to time, provide third parties with data that has been anonymized, which means that your personal information that could be used to identify you have been removed from the data.
Transmission and storage of personal data
Sports Debatable LLC primarily store and process PII data electronically. The company and its employees follow strict protocols in terms of handling and processing data, which meets the requirements of the Information Security standard ISO27001, to which the company is certified.
How long is PII retained?
Sports Debatable LLC will not retain PII for longer than required and we will keep this;
For as long as required by law
Until we no longer have a valid reason for keeping it
Until you request us to stop using it i.e. Right to Erasure
The company has an information retention procedure and schedule, which is monitored and complied with.
Refusal to provide Sports Debatable LLC with personal information
If the personal information is necessary in order to supply goods or services to you under a contract between you and Sports Debatable LLC, then we will not be able to enter into that contract or provide the products or services without that information.
- Your Rights
Sports Debatable LLC will respect individual’s legal rights to their data. These cover;
The right to be informed – Sports Debatable LLC is publishing this Privacy Notice to keep you informed as to what we do with your personal information. We strive to be transparent about how we use PII.
The right to access – the right to access your information. Contact Sports Debatable LLC if you wish to access the personal information Sports Debatable LLC holds about you.
The right to rectification – if the information Sports Debatable LLC holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the
The right to erasure – sometimes referred to as ‘the right to be forgotten’. If you want Sports Debatable LLC to erase all your personal data and we do not have a legal reason to continue to process and hold it, please contact
The right to restrict processing – you have the right to ask Sports Debatable LLC to restrict how we process your data. This means we are permitted to store the data but not further process We keep just enough data to make sure we respect your request in the future.
The right to data portability – Sports Debatable LLC must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this effecting the usability of your data. The data must be held by us by consent or for the performance of a contract.
The right to object – Data Subjects have the right to object to Sports Debatable LLC processing their data even if it is based on our legitimate
The right to withdraw consent – If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and Sports Debatable LLC must stop processing your
The right to complain to a higher body – data subjects have the right to complain to the ICO if they feel that Sports Debatable LLC is not meeting its obligations in terms of GDPR or has not responded to their requests to solve a problem.
- Opting Out and Unsubscribing
Reviewing, correcting and removing your Personal Information
Upon request, Sports Debatable LLC will provide you with information about whether we hold any of your Personal Information. If you provide us with your Personal Information, you have the following rights with respect to that information:
To review the user information that you have supplied to us
To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us
To request that your user information not be used to contact you
To request that your user information be removed from any solicitation list that we use
To request that your user information be deleted from our records
To opt out of being solicited by Sports Debatable LLC or third parties
To exercise any of these rights, please email us at email@example.com. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
- Changes to Our Privacy Notice
UPDATED APRIL 28, 2019