This Website collects some Personal Data from its Users.

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Owner and Data Controller

Silikong Baby Products
Gadot 1, Gadot
Zip 12325
Israel
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Phone: +972 54-659-6789
Email: [email protected]

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); email address; first name; last name; phone number; address; state; city.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.

Types of Data collected

Mode and place of processing the Data


Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Advertising, Remarketing and behavioral targeting, Platform services and hosting, Interaction with external social networks and platforms and Contacting the User.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services

  • Advertising

    This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
    This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
    Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.

    Facebook Audience Network (Facebook, Inc.)

    Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook’s use of Data, consult Facebook’s data policy.

    This Website may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User’s ad preferences. The User can control this in the Facebook ad settings.

    Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

    Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

    Google AdSense (Google Inc.)

    Google AdSense is an advertising service provided by Google Inc. This service uses the “Doubleclick” Cookie, which tracks use of this Website and User behavior concerning ads, products and services offered.
    Users may decide to disable all the Doubleclick Cookies by clicking on: google.com/settings/ads/onweb/optout.

    Personal Data processed: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

    Direct Email Marketing (DEM) (this Website)

    This Website uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Website.
    Personal Data processed: email address.

  • Analytics

    The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

    Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

    Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
    Personal Data processed: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy.

    Google Analytics (Google Inc.)

    Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    Personal Data processed: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

    Google Analytics with anonymized IP (Google Inc.)

    Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
    Personal Data processed: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

  • Contacting the User

    Contact form (this Website)
    By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
    Personal Data processed: address; city; email address; first name; last name; phone number; state.
    Mailing list or newsletter (this Website)
    By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
    Personal Data processed: email address; first name.

  • Interaction with external social networks and platforms

    This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.
    The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network.
    This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
    It is recommended to log out from the respective services in order to make sure that the processed data on this Website isn’t being connected back to the User’s profile.

    Pinterest “Pin it” button and social widgets (Pinterest)

    The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.
    Personal Data processed: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy.

  • Platform services and hosting

    These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
    Place of processing: Canada – Privacy Policy.

  • Remarketing and behavioral targeting

    This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
    This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
    Some services offer a remarketing option based on email address lists.
    In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
    Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

    Facebook Custom Audience (Facebook, Inc.)

    Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
    Personal Data processed: Cookies; email address.
    Place of processing: United States – Privacy Policy – Opt Out.

    Facebook Remarketing (Facebook, Inc.)

    Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
    Personal Data processed: Cookies; Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

Further information about Personal Data

MailPoet This Privacy Notice (“Privacy Notice“) describes the privacy practices of MailPoet Inc. and its subsidiaries and affiliates (collectively, “MailPoet” or “us” or “we“).

MailPoet provides marketing technology services to other businesses – our clients. To take advantage of our services, our clients share with us information about their individual consumers, including contact details and shopping histories. We analyze that information and develop and send communications to the consumers only at the direction of the client who provided the information, and only on that client’s behalf. We may also collect personal data for our own business purposes in connection with our business, such as business contact details of potential customers or job applicants’ resumes. We do not collect employee or HR related data in the EU or Switzerland, or transfer such information either into or out of the EU or Switzerland.

This Privacy Notice applies to:

The klaviyo.com website and any other websites or online services controlled by us and which display this Privacy Notice, and
Marketing technology services that we provide to our clients.
Click on the links below to jump to sections of the Privacy Notice:

Information We Collect
Information We Collect for MailPoet’s Own Business Purposes
Information We Collect from or on Behalf of Our Clients
Cookies and Other Information Collected by Automated Means
Automated Data Collection for MailPoet’s Own Business Purposes
Automated Data Collection on Behalf of Our Clients
Our Use of Personal Information
Our Use of Personal Information for MailPoet’s Own Business Purposes
Our Use of Personal Information on Behalf of our Clients
Information We Share
Careers
Privacy Preferences, Rights, And Choices
International Data Transfers
EU-US Privacy Shield & Swiss-US Privacy Shield Certifications
How We Protect Information
Links To Websites And Third Party Content
Changes To Our Privacy Notice
Data Retention
California Privacy Rights
How To Contact Us
INFORMATION WE COLLECT

Information We Collect for MailPoet’s Own Business Purposes

We may collect information about individuals who interact with MailPoet when using our website or services (such as employees of our clients), job applicants, and other individuals.

How we collect the information

We may collect information:

Directly from individuals
From third party vendors, data brokers, or business partners
From recruiters
Types of information we collect

The types of information we collect include:

Personal and business contact information (such as name, business name, address, telephone number, email address, and mailing address)
Payment information (such as credit card or other financial account numbers)
We do not collect employee or HR related data in the EU or Switzerland, or transfer such information either into or out of the EU or Switzerland.
Information We Collect from or on Behalf of Our Clients

We may collect information about individual consumers from our clients or – at clients’ request– from their service providers. Our clients determine the scope of the information transferred to us, and the information we receive may vary by client. Typically, we may collect clients’ consumers’ contact details and demographic data, shopping histories, and details about consumers’ interactions with marketing communications.

COOKIES AND OTHER INFORMATION COLLECTED BY AUTOMATED MEANS

We, our service providers, and our business partners, may collect certain information about the use of our websites by automated means, such as cookies, web beacons and other technologies. Likewise, as part of our services, we may offer our clients the ability to install these types of technologies on their websites or in the emails they send to their customers; and if a client does so, we collect information on its behalf. A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. We and our service providers and business partners may collect information about your online activities over time and across third-party websites when you use our websites and mobile applications.

Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Please see the “Privacy Preferences, Rights and Choices” section below for information about how you may opt out of, or limit the use of, your browsing behavior for online behavioral advertising purposes.

The information we collect by automated means varies based on whether we are collecting information for our own business purposes or whether we are collecting information from or on behalf of our customers to provide our services.

Automated Data Collection for MailPoet’s Own Business Purposes

The information collected by automated means for our own business purposes includes:

Details about the devices that are used to access our websites (such as the IP address, and type of operating system and web browser)
Dates and times of visits to, and use of, our websites
Information about how our websites are used (such as the content that is viewed on our websites and how users navigate between our webpages, and the date and time of access)
Details about how individuals interact with our emails (such as whether the email is opened and which links are clicked in the email)
URLs that refer visitors to our websites
Search terms used to reach our websites
Web browsers may offer users of our websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly.

Automated Data Collection on Behalf of Our Clients

The information collected by automated means on behalf of our clients may include:

Details about the devices that are used to access our clients’ websites (such as the IP address, and type of operating system and web browser)
Dates and times of visits to, and use of, our clients’ websites
Information about how our clients’ websites are used (such as the content that is viewed on our clients’ websites and how users navigate between webpages, and the date and time of access)
Details about how individuals interact with our clients’ emails (such as whether the email is opened and which links are clicked in the email)
URLs that refer visitors to our clients’ websites
Search terms used to reach our clients’ websites
Web browsers may offer users of our clients’ websites the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly.
OUR USE OF PERSONAL INFORMATION

Our Use of Personal Information for MailPoet’s Own Business Purposes

We may use personal information to:

Provide our services to our clients
Communicate about the products and services we offer, and respond to requests, inquiries, comments, and suggestions
Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read)
Operate, evaluate and improve our business, our websites, and other products and services we offer (including to develop new products and services)
Invoice and collect payment for our services
Establish and maintain an individual’s profile in our service
Tailor the content we display in our communications, in our services and in mobile apps
Administer surveys and other market research
Comply with legal requirements, judicial process, and our company policies (including to verify users’ identity in connection with access or correction requests)
Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide
Process employment applications
Monitor recruiting statistics, to inform our recruitment activities
We may aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.

Our Use of Personal Information on Behalf of our Clients

We use personal information we collect from or on behalf of our clients to provide services to our clients at their direction. We do not use this information for MailPoet’s own purposes. We use personal information only as directed or authorized by our client. Typically, we are directed or authorized to use personal information collected on behalf of the client to:

Help customize marketing strategy for our clients
Personalize marketing content for our clients’ customers
Target customers for our clients’ marketing campaigns
Analyze and enhance our clients’ communications and strategies (including by identifying when emails sent to you have been received and read)
Analyze results from marketing campaigns for our clients
INFORMATION WE SHARE

We may share personal information for the purposes set out in this Privacy Notice with:

Service providers that perform services on our behalf, such as technology providers (including providers of payment processing, technology support, web hosting, and email communications)
Survey and market research providers
Advertising and marketing partners
Analytics organizations
Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will – where required by applicable law – make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Notice. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.

In addition, we may share your information to comply with legal and regulatory requirements, and protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.

PRIVACY PREFERENCES, RIGHTS, AND CHOICES

Individuals have certain rights and choices regarding MailPoet’s processing of their personal information. Please note, however, that if the exercise of these rights limits our ability to process personal information, we may be precluded from providing our products or services to individuals who exercise these rights, or from otherwise engaging with such individuals going forward.

Individuals whose personal information MailPoet processes on behalf of a client should contact that client to exercise the rights and choices described in this section.

We reserve the right to verify the identity of the individual in connection with any requests regarding personal information to help ensure that we provide the information to individuals to whom the information pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.

For information about the rights and choices users have with respect to cookies and online tracking, please see the “Cookies and Other Information Collected by Automated Means” section of this Privacy Notice.

General Objections to the Processing of Personal Information

To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to MailPoet’s use or disclosure of your personal information will mean that MailPoet will not be able to provide products or services to you or to otherwise engage with you.

Access to Personal Information

You may request access to correct, amend, or delete the personal information that we maintain about you. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business, in a commonly used format. You may request to correct any errors in your personal information. We may reject your request to access or correct your information, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection. If you wish to exercise this right please contact us here at [email protected]

We will also provide an EU or Swiss individuals with opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.

To limit the use and disclosure of your personal information, please submit a written request to [email protected]

Portability of Personal Information

You may request that we transfer your personal information to another data controller. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.

Deletion of Personal Information

You may request that we delete your personal information. We may reject your request, as permitted by applicable law. If we reject your request, we will notify you of the reasons for the rejection.

Marketing Emails

You may unsubscribe from receiving marketing or other commercial emails from MailPoet by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our website terms).

Online Behavioral Advertising

Some of the business partners that collect information about users’ activities on our websites may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior for purposes of targeted advertising. For example, users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

INTERNATIONAL DATA TRANSFERS

We may transfer personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. For example, if you are located outside of the United States, we typically transfer your personal information to the United States, where MailPoet is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information.

EU-US PRIVACY SHIELD & SWISS-US PRIVACY SHIELD CERTIFICATIONS

MailPoet participates in the EU-US Privacy Shield framework and Swiss-U.S. Privacy Shield framework.

MailPoet complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and/or Switzerland to the United States. MailPoet has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In particular, if MailPoet transfers to its service providers any personal information that MailPoet received in reliance on its Privacy Shield certification, MailPoet is responsible for the third parties’ processing of that personal information, unless MailPoet proves that it is not responsible for the event giving rise to the damage. Please be aware that MailPoet may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

MailPoet is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

MailPoet has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

As further explained in the Privacy Shield Principles more fully described here, you may be entitled to invoke binding arbitration pertaining to certain residual complaints that have not been resolved by any other means.

HOW WE PROTECT INFORMATION

We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information we maintain against accidental, unlawful, or unauthorized access, disclosure, alteration, use, loss, or destruction. However, we cannot guarantee that the safeguards we maintain will ensure the security of the personal information.

LINKS TO OTHER WEBSITES AND THIRD-PARTY CONTENT

We may provide links to websites and other third-party content that is not owned or operated by MailPoet. The websites and third-party content to which we link may have separate privacy notices or policies. MailPoet is not responsible for the privacy practices of any entity that it does not own or control.

CHANGES TO OUR PRIVACY NOTICE

MailPoet reserves the right to change this Privacy Notice at any time. When we update this Privacy Notice, we will notify you of changes that are deemed material under applicable legal requirements by updating the date of this Privacy Notice and providing other notification as required by applicable law. We may also notify you of changes to the Privacy Notice in other ways, such as via email or other contact information you have provided.

DATA RETENTION

We will retain personal information only for as long as necessary to fulfill the purpose(s) for which the information was collected, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may govern the retention of the data, and our legal or regulatory obligations. We will then destroy the personal information or anonymize the information, in accordance with applicable law.

CALIFORNIA PRIVACY RIGHTS

California law permits visitors who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at [email protected]

Privacy Policy

This Privacy Policy was last updated on May 18, 2018. If you want an easier to digest format, read our Data Promise instead.

This website (the “Site”) is operated by Privy, Inc. (“Privy”, “we”, “us” and/or “our”) and has been created to provide our Site visitors (“you”, “your”) with information about our company and our e-mail collection tools. This Privacy Policy (this “Policy”) sets forth Privy’s policy with respect to information, including personally identifiable data (such personally identifiable data “Personal Information”), that is collected from you through the Site or through our other service offerings (collectively, including the Site, the “Services”). Certain Services may be made available to you on websites owned by our end customers (each, an “End Customers”), and the information collected via these embedded widgets (“Tools”) is directed to Privy and governed by this Policy.

The Services and our business may change from time to time. As a result, at times it may be necessary for Privy to make changes to this Policy. Privy reserves the right to update this Policy at any time and from time to time without prior notice. Please review this Policy periodically, and especially before you provide any Personal Information. This Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Policy shall indicate your agreement with the terms of such revised Policy.

1. Information Collected
When you interact with us through the Site or other Services, we may collect Personal Information and other information from you, as further described below:

Personal Information That You Provide:
We collect Personal Information from you when you voluntarily provide such information, such as when you contact us with inquiries, subscribe to our or a Privy End Customer’s e-mail newsletter, register for access to the Services or use certain Services. For instance, Privy may collect the following information about you: name, address, zip code, telephone number and e-mail address. The information collected may vary. For example, our End Customers may customize the data that is requested via the Tools and may collect other information, such as your favorite color or birthdate. Wherever Privy collects Personal Information we make an effort to provide a link to this Policy.

By voluntarily providing us with Personal Information, you are consenting to our use of it in accordance with this Policy. If you provide Personal Information to the Site or through the other Services, you acknowledge, agree, and expressly consent that such Personal Information may be transferred from your current location to the offices and servers of Privy and the authorized third parties referred to herein located in the United States.

Other Information:
Non-Identifiable Data: When you interact with Privy through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you, unless it is combined with Personal Information. Privy may store such information itself or such information may be included in databases owned and maintained by Privy affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that Privy uses no Personal Information in this process.

Cookies: In providing the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site or the Tools. Our cookies help provide additional functionality to the Services and help us analyze the Services usage more accurately. Certain information collected through the use of cookies may be used to serve you more relevant online advertisements by us or third parties. We may, or a third party may, place and recognize a unique cookie on your browser specifically to identify you for the purposes of providing you with customized ads or content across channels. The cookies may be linked to data you voluntarily submit to us, e.g., your email address, which we may share with a third party. If we share such Personal Information, it will be in hashed, non-human readable form for security purposes only. If you’d like to opt-out of such collection and use of data, please go to the Digital Advertising Alliance’s consumer opt-out page here: www.aboutads.info/choices or the Network Advertising Initiative’s opt-out mechanism here: http://networkadvertising.org/optout_nonppii.asp. For the avoidance of doubt, except with respect to EU Data, we may share with third party’s data collected from your use of websites of End Customers with third parties and such third parties might use that data, together with data collected by such third parties from other sources to cause advertisements to be targeted to you. Such data typically includes the URL you are on. As used herein, “EU Data” means data of data subjects located in the European Economic Area (including the United Kingdom as of the Effective Date of this Privacy Policy).

In addition, you can generally inform the web services with which our Services integrate (such as social buttons, widgets, and other embedded features or content) that you do not want certain information about your webpage visits to be collected. Enabling “Do Not Track” in your web browser settings is an easy way to accomplish this. The “Do Not Track” browser setting is supported by recent versions of major browsers, including Firefox 5+, Internet Explorer 9+, Safari 5.1+, and Google Chrome. Please consult http://donottrack.us on how to enable this privacy setting on your browser. You can also change the way your browser handles cookies. Already existing cookies can be deleted. Please consult www.allaboutcookies.org on how to manage or delete cookies in your browser. This Policy covers the use of cookies and similar files by Privy only and does not cover the use of cookies, flash cookies, and similar files by any third-party advertisers or websites linked to the Site. We also may use Google Analytics and other similar services. Google Analytics uses cookies to help analyze how users use the Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google, Inc. (“Google”). Google will use this information for the purpose of evaluating your use of the Site, 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.

Aggregated Personal Information: In an ongoing effort to better understand and serve the users of the Services, Privy often conducts research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Privy may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Privy may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

2. Use of Information:
Privy uses the Personal Information you provide in a manner that is consistent with this Policy. If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For instance, if you contact us by e-mail, we will use the Personal Information you provide to answer your question or resolve your problem. In addition to the foregoing purposes, we and our affiliates may use your information to: (a) improve the content and functionality of the Services; (b) better understand our users; (c) improve our marketing and promotional efforts and customize the Services content, layout, and Services to better suit your needs; and (c) resolve disputes, troubleshoot problems and enforce our Service Terms (as defined below).

In addition, Privy and its affiliates may use your information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us as indicated.

3. Disclosure of Information
There are certain circumstances in which we may share your Personal Information or other information with third parties without further notice to you, as set forth below:

End Customers: If you enter your Personal Information in any Tool on an End Customer’s website, we may share such Personal Information with the applicable End Customer and such End Customer’s service providers, as requested by such End Customer.

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.

Related Companies: We may also share your Personal Information with our affiliates for purposes consistent with this Policy.

Agents, Consultants and Related Third Parties: Privy, like many businesses, sometimes hires other companies or individuals to perform certain business-related functions. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: Privy may disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, including lawful requests by public authorities, including to meet national security or law enforcement requirements, (b) protect and defend the rights or property of Privy, (c) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (d) protect against legal

4. Security
Privy takes reasonable steps to protect the Personal Information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Site may not be secure. Therefore, you should take special care in deciding what information you send to us via e-mail. Please keep this in mind when disclosing any Personal Information to Privy via the Internet.

5. Third Party Sites
This Policy applies only to the Services. The Site and other Services, including the Tools, may contain links to other websites not operated or controlled by Privy, including those operated by End Customers (the “Third Party Sites”). The policies and procedures described here do not apply to the Third-Party Sites or services, or to the use of information submitted via a Tool on such End Customer’s website by the applicable End Customer or its service providers. The links from the Site or placement of Tools on certain Third-Party Sites does not imply that Privy endorses or has reviewed the Third-Party Sites. We suggest contacting those sites, services, entities or persons directly for information on their privacy policies.

6. Children’s Online Privacy Protection
Privy does not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Policy by instructing their children never to provide Personal Information through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to Privy, please contact us, and we will endeavor to delete that information from our databases.

7. Exclusions
This Policy does not apply to any Personal Information collected by Privy other than Personal Information collected through the Services. This Policy shall not apply to any unsolicited information you provide to Privy through the Services or through any other means. This includes any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Privy shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

8. Access to Information; Contacting Privy
To keep your Personal Information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via the Services. Please also feel free to contact us if you have any questions about this Policy or the information practices of this Site. You may contact us as follows: [email protected]

9. Your California Privacy Rights
Applicable California privacy legislation permits visitors who are California residents to request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request to access such information, please contact us as follows: [email protected] Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.

10. EU Personal Data
With respect to the processing of personal data relating to data subjects located in the European Economic Area (including the United Kingdom as of the Effective Date of this Privacy Policy) by Privy solely on behalf of the End Customer, the terms of the Data Processing Addendum shall apply. The following terms have the meanings given in the General Data Protection Regulation (EU) 2016/679 (“GDPR”): “personal data”, “data subject” and “process”.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

This document informs Users about the technologies that help this Website to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with this Website.
For simplicity, all such technologies are defined as “Trackers” within this document – unless there is a reason to differentiate.
For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.
Some of the purposes for which Trackers are used may also require the User’s consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.
This Website uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.
The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.
In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information – such as the presence of other Trackers – in the linked privacy policies of the respective third-party providers or by contacting the Owner.

Activities strictly necessary for the operation of this Website and delivery of the Service

This Website uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.

Other activities involving the use of Trackers

Experience enhancement
This Website uses Trackers to provide a personalized user experience by improving the quality of preference management options, and by enabling interaction with external networks and platforms.

  • Interaction with external social networks and platforms

    This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.
    The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network.
    This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
    It is recommended to log out from the respective services in order to make sure that the processed data on this Website isn’t being connected back to the User’s profile.
    Pinterest “Pin it” button and social widgets (Pinterest)
    The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.
    Personal Data processed: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy.
    Measurement
    This Website uses Trackers to measure traffic and analyze User behavior with the goal of improving the Service.

  • Analytics
    The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
    Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)
    Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
    Personal Data processed: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy.
    Google Analytics (Google Inc.)
    Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    Personal Data processed: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

  • Anonymized analytics services
    The services contained in this section allow the Owner, through the use of third-party Trackers, to collect and manage analytics in an anonymized form.
    Google Analytics with anonymized IP (Google Inc.)
    Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    This integration of Google Analytics anonymizes your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
    Personal Data processed: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

    Targeting & Advertising
    This Website uses Trackers to deliver personalized marketing content based on User behavior and to operate,
    serve and track ads.

  • Advertising
    This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
    This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
    Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
    In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies by visiting the Network Advertising Initiative opt-out page.
    Facebook Audience Network (Facebook, Inc.)
    Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook’s use of Data, consult Facebook’s data policy.
     
    This Website may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User’s ad preferences. The User can control this in the Facebook ad settings.
     
    Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.
    Personal Data processed: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

    Google AdSense (Google Inc.)
    Google AdSense is an advertising service provided by Google Inc. This service uses the “Double-click” Cookie, which tracks use of this Website and User behavior concerning ads, products and services offered.
    Users may decide to disable all the double-click Cookies by clicking on: google.com/settings/ads/onweb/optout.
    Personal Data processed: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

  • Remarketing and behavioral targeting

    This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
    This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
    Some services offer a remarketing option based on email address lists.
    In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
    Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
    Facebook Custom Audience (Facebook, Inc.)
    Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
    Personal Data processed: Cookies and email address.
    Place of processing: United States – Privacy Policy – Opt Out.

    Facebook Remarketing (Facebook, Inc.)
    Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
    Personal Data processed: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

    AdRoll (AdRoll, Inc.)
    AdRoll is an advertising service provided by AdRoll, Inc.
    Personal Data processed: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy – Opt Out.

    Activities that do not fit the above categorizations
    How to manage preferences and provide or withdraw consent

    There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:
    Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.
    Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences widget, if available.
    It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent.
    Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.
    With regard to any third-party Trackers, Users can manage their preferences and withdraw their consent via the related opt-out link (where provided), by using the means indicated in the third party’s privacy policy, or by contacting the third party.
    Locating Tracker Settings
    Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:

    Google Chrome
    Mozilla Firefox
    Apple Safari
    Microsoft Internet Explorer
    Microsoft Edge
    Brave
    Opera

    Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings, such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings, view and look for the relevant setting).
    Advertising industry specific opt-outs
    Notwithstanding the above, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

    The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
    Since the use of third-party Trackers through this Website cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.
    Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by this Website.

Definitions and legal references

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.


Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.


Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.


This Website (or this Application)

The means by which the Personal Data of the User is collected and processed.


Service

The service provided by this Website as described in the relative terms (if available) and on this site/application.


European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.


Cookie

Cookies are Trackers consisting of small sets of data stored in the User’s browser.


Tracker

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Website, if not stated otherwise within this document.