Aventri Privacy Policy

1. About this Privacy Policy.

This Privacy Policy applies to information that Aventri may collect about you in connection with your access and use of the Aventri websites located at www.Aventri.com, www.eiseverywhere.com, and www.eventscloud.com (together with any other websites and domains operated by us and from which you are accessing this Privacy Policy, the “Websites”), the Aventri cloud-based event management and registration platform (the “Platform”), our social media pages, mobile apps, Smart Tags and any other products and services offered by Aventri (collectively, “Services”), as well as through email messages that we send to you that link to this Privacy Policy, and other communications (for example, customer support requests, surveys, and SMS texts) in which you may provide personal data to Aventri. In this Privacy Policy, the Websites, Platform, mobile apps, Smart Tags, social media pages, emails, and other electronic locations through which you may interact with Aventri to provide your information are collectively referred to as the “Sites.”

This Privacy Policy does not apply to third party applications or software that integrates with the Services through the Sites, or any other third party products, services, or websites.

If you do not agree with this Privacy Policy please do not access or use the Sites or Services.

2. Who We Are.

As used in this Privacy Policy, “Aventri” refers to Aventri, Inc., together with its US-based and international affiliates (Loopd, Inc.; Zentila, Inc.; Aventri (UK) Ltd.; Aventri Asia Pacific Pty. Limited; Aventri India Private Ltd.; ITN International LLC; ITN Technologies Corp.; and TapCrowd BVBA).

“You” refers to individuals who access and use the Sites and/or Services. For example, you may be a client of Aventri who accesses and uses the Sites and Services as the host or organizer of an event (“Client”), and with whom Aventri has entered a Subscription Services Agreement or other agreement containing separate terms and conditions that govern delivery, access and use of the Sites and Services (a “Client Agreement”). You may be the employee or agent of a Client, who is authorized to access the Platform as an administrator. Or, you may be a visitor to our Website who is just interested in browsing and learning more about Aventri.

If you are invited to, register for, check into, or receive information regarding a Client event through an Aventri Site or Service, you will be considered an “Event Attendee” and we will provide any Personal Information you submit through the Site or Service to the Client organizing that event. Aventri does not control the Client’s event registration or management process, or the Personal Information that a Client requests from Event Attendees. We are not responsible for any decisions or actions taken by the Client with respect to your information (or by any third party with whom the Client may share your information). Please read the applicable privacy policies of the Client who is organizing the event before submitting Personal Information in connection with that event.

When we collect information from you, we may be doing so on our own behalf (in which case we will be considered a “controller” of your data), or on behalf of an Aventri Client who is using the Services to organize an event and manage other event-related activities (in which case, the Client will be the “controller” and Aventri will be considered a “processor” of your data).

3. What Types of Information Does Aventri Collect?

This section describes the various kinds of information that Aventri may collect and store when you interact with us through the Sites and/or Services.

Personal Information

“Personal Information” is any information collected on or through our Sites and/or Services that may be used to identify or personally contact you or another individual, or that relates to an identified person. Personal Information may include, but is not limited to, name, job title, company name, email address, mailing address, phone number, browser and device information (including IP Address), payment data and other identifying information you may provide to Aventri.

You are not required to provide Aventri with any Personal Information. However, certain Aventri Services and Site functionalities may not be available to you unless some Personal Information is provided by you, or by a Client or Client administrator on your behalf.

If you are submitting Personal Information relating to any other person (including as a Client administrator, or on behalf of other individuals at your company), you represent that you have full authorization to provide this information to Aventri, and to permit us to use it in compliance with this Privacy Policy.

With respect to the Personal Information of EU residents, Aventri complies with applicable requirements of the General Data Protection Regulation (EU) 2016/679 as it applies to personal data.

Other (Non-Personal) Information

Non-Personal Information includes any information that is anonymized, aggregated or otherwise presented in a way that does not allow identification of a specific individual, or is not directly associated with a unique person.

To the extent that any Non-Personal Information is integrated with Personal Information, it will be considered Personal Information for purposes of this Privacy Policy.

4. How Aventri Collects Information.

From our Websites

If you visit one of our Websites and request a free demo, register for a webinar, subscribe to our blog, ask for Service information or download content (such as a whitepaper), you will be asked to provide certain Personal Information, including your contact details.

1. We will use this Personal Information for purposes such as answering questions regarding our Service offerings, or initiating a sales dialogue.

From our Platform

1. Information collected via the Aventri Platform (including on Mobile Apps) is collected from or on behalf of our Clients who are hosting or managing events. This information is either collected from Client administrators who access the back-end of our Platform, or from Event Attendees.
2. This type of Personal Information is controlled by the Client, and Aventri only collects and processes it at the Client’s direction, in accordance with instructions provided by the Client, including applicable terms in any Client Agreement. With respect to this type of information, Aventri is a processor, and Client is the controller. Aventri works together with Clients and offers tools so that Clients can provide appropriate notice regarding the purposes for which they are collecting Personal Information on our Platform, and so that Client can also obtain consent to the collection and use of such information, where appropriate.

From Offline Interactions

1. We may request and collect your Personal Information offline as well - for example, when you attend an Aventri promotional event or a Client event, or if you call one of our sales representatives for information about our product offerings.

From Other Online Sources

1. Surveys – We may ask you to participate in a survey, and your responses could contain Personal Information.
2. Blogs - Our Website offers publicly accessible blogs and user forums. If you choose to comment or participate on these, please be aware that any information you provide in these areas may be read and used by other members of the public who access them. To request removal of your personal information from our blog or any Aventri forum, contact us at support@aventri.com. In some cases, we may not be able to remove your personal information from these areas, in which case we will let you know if we are unable to do so and why.
3. In connection with your use of the Site and/or Services, we may also request occasional information about your interests and preferences, to better provide communications, offers and content that are specifically tailored to your personal interests.

Automatic Information

1. As is true of most websites, we gather certain information automatically when you visit our Sites, such as your computer type (MAC or Windows), mobile device type, language, internet browser, any web pages that referred you to our Site, and your Internet Protocol (IP) Address (which may be identified and logged automatically in our server log files whenever you visit the Websites or Platform). We may also store general usage and activity data, such as the date and duration of your visit, and your navigation of the Site. We use this information for reasons such as improving Site performance, analytics, and functionality, and monitoring the regions from which users access our Websites or Platform, in order to help us enhance the user experience and Site security.
2. Cookies, beacons, tags and scripts may also be used by Aventri and our integration partners or analytics and service providers. These technologies are used in analyzing trends, administering the Sites, tracking users’ movements around the Platform and to gather demographic information about our userbase as a whole. We may receive reports based on the use of these technologies by our partners or providers on an individual as well as aggregated basis.

From Mobile Apps

1. When you download or use a mobile app created by Aventri in connection with a Client event, we collect app usage data, including which of our apps have been downloaded to your mobile device and when.
2. If, where applicable, you have requested or consented to location services in connection with your use of a mobile app, we may receive information about your location and your mobile device. We use this information to provide you with location-based Services and other personalized content based on your location. Most mobile devices enable you to shut off location-based services; please access your mobile device’s “Settings” for more information.

From Smart Tags

1. If are an Event Attendee wearing an Aventri Smart Tag at a Client event, the Smart Tag will collect data regarding your attendance at that event, including what time you check in and out, which sessions you attend, what exhibitors and event locations you visited, and with whom you exchanged contact information using the Smart Tags.

From Email messages

1. If you contact an Aventri representative using our customer service email, or any one of our informational email mailboxes (e.g., gdpr@Aventri.com, sales@Aventri.com), we will store information such as the email address from which you sent the message, and use the information to reply to you.

From Other Sources

1. In order to better provide you with marketing offers and additional services that are of interest or relevant to you, we obtain information from other sources, including public databases, marketing partners, social media platforms and other third parties.
2. Social Media features and Widgets. Our Web site includes Social Media features, such as the Facebook “Like” button, and Widgets, such as the “Share This” button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the applicable feature or widget to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy (whether Aventri, Facebook, Instagram, or some other third party) of the company providing the feature, and you must contact them with any requests you may have for access, modification or deletion of your Personal Information.

Information from Cookies.

1. Aventri may collect additional information through the use of “cookies” which are small data files placed on your computer’s hard drive to assign an identification code to your computer. Aventri may use cookies for reasons including, but not limited to, identifying a registered user who logs into any Aventri Service through the Platform, enabling certain customized features, and storing your user preferences. We may also use cookies to collect aggregated user information that Aventri utilizes to improve the general operation of its Sites and Services. You may set your computer’s browser preferences to remove and disable cookies. But please note that some features of the Sites or Services may not be accessible or operate properly if you disable your cookies. For more details about how we use cookies, please review our Aventri Cookie Policy.

5. What Legal Basis Does Aventri Have for Collecting and Processing My Personal Information?

Aventri’s legal basis for collecting and using the types of Personal Information described above will depend on the nature of the Personal Information, and the context in which we are collecting it. When we collect, use, process or disclose your Personal Information, we will rely on one or more of the following legal grounds:

• Performance of a contract (including any Client Agreement) – Where we need the Personal Information to perform our obligations under a Client Agreement or other binding contract.
• Consent – Where we have received your consent to do so.
• Legitimate Interests – Where it is in our legitimate business interests; for example, to improve our products and services.
• Legal Requirement – If we are required to collect, use, process or disclose your Personal Information due to a legal or regulatory requirement, we may do so.

6. How Does Aventri Use Personal Information?

Aventri may use your Personal Information:

• To respond to your inquiries and fulfill your requests, and to provide you with customer support when you ask for it.
• To send you updates, newsletters and other content that you have requested or subscribed to, as well as informational materials regarding our Services.
• To provide you with technical and administrative information relating to our Sites and Services, such as security notices, Service-related status reports, and changes to our policies or terms of use. Please note that these communications are considered part of our Services and you may not opt out of them.
• If you have consented and it is in compliance with applicable laws, to send you marketing communications regarding products and services that we believe may be of interest to you. If you later decide that you no longer want to receive this type of marketing or promotional information, you may opt-out at any time by clicking the “Unsubscribe” button at the bottom of the marketing communication, or contacting us at the email or mailing address provided in the “Contact Information” section of this Privacy Policy.
• To personalize your experience on the Sites by offering content tailored to your preferences.
• For our internal business purposes that include administering your access and use of any Aventri Services, data analysis, securely identifying you when you log onto a Service, fraud monitoring and prevention, enhancing or modifying our Sites and Services, determining the effectiveness of our promotional campaigns, billing you for Services, and operating our business.
• As necessary for us to comply with applicable law.

Also, please note that if information is aggregated or anonymized so that it is no longer reasonably associated or trackable to an identifiable natural person, it is no longer considered “Personal Information” under this Privacy Policy and Aventri may use it for any legitimate and lawful business purpose.

7. Profiling and Automated Decision Making

Information you provide to us may be combined, analyzed or processed in a manner that helps us predict and determine your interests and preferences, including what products and services may be of interest to you, and when you might be ready to take certain steps (such as ordering a particular Service), based in part on your behaviors on the Sites and interactions with Aventri. This process is overseen by Aventri staff, and no automated decisions are made that would result in legal effects or have a significant impact on you or any individual accessing the Sites or Services.

8. How will Aventri Share Personal Data with Others?

This section describes how Aventri shares or transfers the Personal and Non-Personal Information it collects about you, as well as your ability to control how your information is shared with others.

1. Personal Information. Except as provided in this Privacy Policy, Aventri will not disclose, transfer, sell, trade, rent, or otherwise provide your Personal Information to any third party, without your consent.
2. Aggregated Data. Aventri may share aggregated, non-personally identifying information, log data and usage statistics with third parties for purposes including demographic, industry and marketing analysis.
3. Subsidiaries and Affiliates. Aventri discloses Personal Information to its subsidiaries and affiliates for the purposes described in this Privacy Notice. Aventri, Inc. is the entity responsible for the management of Personal Information shared among Aventri subsidiaries and affiliates.
4. Service Providers. Aventri may use third party contractors to provide certain services and perform functions on our behalf. Examples include providing cloud-hosting capabilities, offering chat-bot functionality, processing credit card payments, providing marketing assistance, and performing statistical analysis relating to usage of our Sites and Services. Aventri may provide your Personal Information only to the extent necessary for such third party service provider to perform the duties for which it has been retained by Aventri. Any such third parties will be bound to strict confidentiality and use obligations with respect to your Personal Information, which are no less protective than those set out in this Privacy Policy.
5. Clients. If you are accessing any Site or Service as an administrator or authorized user of a Client, or as an Event Attendee for an event organized by a Client, Aventri is permitted to provide the Client with your information, including but not limited to your Personal Information, access information and usage data.
6. Legal and Contractual Compliance. Aventri may disclose your information to government or law enforcement officials, regulatory agencies or other third parties (such as attorneys or regulatory service providers), as necessary to (i) comply with applicable laws or regulations, (ii) cooperate with governmental or law enforcement investigations, (iii) respond to legal claims or processes, (iv) protect the safety and legal rights of the public or any individual, (v) detect, prevent or remedy any suspected fraud, market manipulation or illegal, tortious or wrongful activity; or (vi) enforce applicable Client Agreements or other Aventri contracts to which you have agreed. However, this does not include selling, renting or sharing or otherwise disclosing Personal Information for commercial purposes in a way that is contrary to the commitments made in this Privacy Policy.
7. Business Transfers. If Aventri is acquired by, acquires or is merged with another company, Aventri may transfer Personal and Non-Personal Information about you to such company. However, in the event of such a transfer, your information will remain subject to the protections of this Privacy Policy. Aventri will notify you if your information is subject to a business transfer and becomes subject to the other company’s privacy policy.
8. Third Party Websites and External Links. Our Sites may contain links to websites (including social media sites) owned and operated by third parties. When you click on such links, you may leave our Website and be directed to the third parties’ websites. These websites may themselves collect Personal Information about you. If you submit information to any of those sites, your information is governed by their privacy policies, which may differ from those of Aventri. Aventri is not, and will not be, responsible for the privacy practices or security of any such websites, and we urge you to read their privacy policies carefully.
9. Our Blogs and Social Media Pages. As we discuss above, you may disclose Personal Information during your participation in our Blogs or on Social Media Sites, including on message boards, in chats, and on any social media site on which you are able to post information and content. This Personal Information may appear in public ways, including through search engines or other publicly available platforms, and can be “crawled” or may be searchable by third parties. Please do not post any information that you do not want to be disclosed to the public.
10. Upon Your Consent. Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to consent to Aventri sharing this information.

9. How Does Aventri Keep My Personal Information Secure?

Aventri makes it a priority to safeguard the security and privacy of your Personal Information. Aventri has implemented appropriate organizational, technical and administrative measures to protect your Personal Information from unauthorized access, disclosure, misuse, alteration or loss. The protective measures we use depend on the sensitivity of the information, and the ways in which we collect, process and store it.

These measures include security controls to prevent unauthorized access to our facilities and systems, strong authentication procedures and strict password protection protocols, utilizing encryption software for all financial and other sensitive Personal Information transmitted on or through our Sites, and conducting penetration tests. We follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive it.

In the event of any security breaches, we will make legally required disclosures to you via email or by providing notice on one or more Sites, as applicable.

While we take reasonable steps to protect your Personal Information, please be aware that no method of Internet transmission or electronic storage guarantees complete protection or is 100% secure, and there is always some risk when you share your Personal Information online. Aventri therefore cannot guarantee the absolute security of your Personal Information.

If you have any questions about security on our Sites, you can contact us at support@Aventri.com.

10. How Can I Access, Correct, Update or Delete My Information?

Depending on your user type and location, we provide you with various ways to access, download and request deletion of your Personal Information.

• If you are a registered user of any Aventri Sites or Services (for example, a Client employee who has been assigned an administrator account on the Platform), you can access, update, modify, correct or delete both Personal and Non-Personal Information by logging onto your user account and visiting your account settings.
• Others may submit requests to access, update, correct or delete their Personal Information, to no longer receive communications, or to “opt-out” of certain Services, by contacting us directly at the Aventri email and/or mailing address provided in the “Contact Information” section of this Policy.
• Please note that Aventri usually has no direct relationship with Event Attendees whose Personal Information Aventri processes on our Platform or through our Services on behalf of a Client (the data controller). If you are an Event Attendee and use our Platform or any Service and would like to access, correct or delete your Personal Information, or would no longer like to be contacted by the Client controlling the information, please direct your request to the Client. If the Client requests that Aventri remove the Personal Information, we will respond to their request in a timely manner.
• • Please be aware that we may need to retain certain Personal and Non-Personal Information for recordkeeping and archival purposes, or to complete any transactions that you initiated prior to requesting such change or deletion.
• If you are a resident of the EU or Switzerland, you have the right to:
  • request access and copies of all of your Personal Information that we possess, in an electronically portable format (e.g., electronic copies of information attached to an email).
  • request that we modify or update any of your Personal Information.
  • request that we delete any of your Personal Information.
  • fully or partially withdraw your consent to the collection, processing, and/or transfer of your Personal Information.

To request access to or copies of your Personal Information, a change to your Personal Information, deletion of your Personal Information, or to withdraw your consent to the collection, processing, and/or transfer of your personal information, contact support@aventri.com. Once we have received notification that you withdraw your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

11. How Long Will Aventri Maintain My Personal Information?

We will only retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and processed, or until you request deletion as described in this Privacy Policy.
Aventri will retain Personal Information we collect from our Clients or Event Attendees, and process on behalf of a Client, for as long as necessary to provide our Services to the Client, and will maintain any such information controlled by a Client in accordance with the Client’s instructions, including any applicable Client Agreement terms, and as required by applicable law.

We will also retain and use Personal Information for a period of time required to comply with our legal, tax, audit or regulatory obligations, to resolve disputes, and to enforce our agreements.
Aventri may retain Non-Personal Information for as long as necessary for the purposes and uses described in this Privacy Policy, including as necessary for Aventri to pursue legitimate and lawful business interests.

12. Children

The Websites, Platform and other Aventri Sites and Services are not intended for children under thirteen (13) years of age. Aventri does not market any products or services to children under thirteen (13) years of age or knowingly collect any Personal Information from children under thirteen (13) years of age. We believe that children should get their parent’s or legal guardian’s consent before providing any Personal Information online.

13. Choices and Opting Out

You have a variety of choices available to you when it comes to your Personal Information. In order to help you exercise those choices, we will inform you, at the time we collect your Personal Information, whether your provision of the information is required or optional, and what the results may be if you do not provide your Personal Information.

• You can always choose not to provide information, even though that means you might not be able to access certain Services or take advantage of certain Site features offered by Aventri.
• You may have consented to receive certain communications marketing or advertising Aventri Services and other products, in accordance with your marketing preferences. You can opt-out of receiving these marketing messages at any time by clicking on the “Unsubscribe” link at the bottom of any such message, or by contacting us at the email and/or mailing address provided in the “Contact Information” section of this Policy.
• Clients may use our Services to send you emails and other electronic communications, if you are on their email subscription lists or have registered for one of their events. Although these messages are sent using our Services, we don’t determine the content or recipients of these messages. You should contact the Client directly, or click the “Unsubscribe” link provided in messages, if you no longer want to receive communications from that Client.
• Even if you have opted to “Unsubscribe” from certain types of messages, please be aware that emails and other communications that respond to your specific requests for information, or are provided as part of the Services you are still receiving, will be sent to you.  You should contact us directly if you no longer wish to receive these responsive or transaction-related communications; but please be aware that if you “opt out” of these types of communications, you may no longer receive important messages regarding events that you are organizing or attending, or critical notifications regarding your Services.

14. Third Party Sites

Our Sites may include links to other websites whose privacy practices differ from those of Aventri. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Also, please be aware that we are not responsible for the collection, use and disclosure policies (including privacy practices) of other companies, such as Facebook, Google, Instagram, Twitter, Apple or any other app developer, app store, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information that may be disclosed to such companies in connection with your use of our social media pages, Aventri’s mobile apps, or other Sites or Services offered by Aventri.

15. Sensitive Information

Where we are collecting, storing and processing information on our own behalf, as a data controller, we will not request any sensitive Personal Information such as your health history, race, religion, or sexual orientation. We request that you do not send us such sensitive Personal Information on or through the Sites, by email, or through any other means.

16. EU Data Transfers; Privacy Shield

Aventri, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, United Kingdom and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov (https://www.privacyshield.gov/)].

Aventri, Inc. is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Aventri, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, UK and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Aventri, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Aventri, Inc. commits to resolve complaints about our collection or use of your personal information. EU, UK and Swiss individuals with inquiries or complaints regarding our Private Shield policy should first contact Aventri, Inc. at:

Aventri
13 Marshall Street
Norwalk, Connecticut 06854 USA
E-mail: support@aventri.com
Phone: 1-877-386-8248

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Aventri, Inc. has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint (you may find DPA contact information in the “Contact Information” section below). The services of EU DPAs are provided at no cost to you.

17. Questions, Concerns, Complaints – Contact Information.

Your privacy is important to us. If you have any questions or concerns about privacy at Aventri, please contact us, and we will try to answer your question or resolve any issues for you.

You may contact us using the following information:

Aventri, Inc.
13 Marshall Street
Norwalk, Connecticut 06854 USA
E-mail: support@aventri.com
Phone: 1-877-386-8248

If you think we have not followed our Privacy Policy in some way, please contact Aventri Customer Support, using the information above. We take seriously any complaint, and it will be assessed by qualified staff with the goal of resolving it in a timely manner.

Subject to applicable law, you also have the right to lodge a complaint with your local data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. (You can find contact information here: EU Data Protection Authorities)

If you are an Event Attendee, please direct any questions you may have regarding your Personal Information to the Client organizing the event, not to Aventri. As noted previously in this Privacy Policy, if you are an Event Attendee for an event organized by an Aventri Client, Aventri processes your Personal Information on behalf of that Client. The Client determines what Personal Information to request from you, how it is used, with whom it may be shared, and for how long it is retained.

18. Amendments to Privacy Policy

Our business is constantly evolving and, therefore, our Privacy Policy may be updated from time to time. Please visit this section of the Site periodically to check for changes and updates to the Privacy Policy. If we make significant changes to this Privacy Policy, we may notify you either through the email address you have provided to us (unless you have instructed us not to), or by placing a prominent notice on our Website. If we materially revise our Privacy Policy, we will provide notice prior to its becoming effective. By continuing to access and use the Sites and/or any Service after such notice, you agree to be bound by the terms of the revised Privacy Policy. Information you submit to aventri is controlled by the privacy policy in effect at the time you submit it.

LAST UPDATED: 15 August 2018