Last updated 01/03/2019

Privacy Policy

What this Policy Covers

esbconnect is a digital marketing company. We work with over 150 High St brands and provide you with personalised marketing content from these brands via email and social. Our aim is to provide you with offers and content that we believe may be relevant to you. To see a list of types of brands we work with, CLICK HERE

 

To see examples of the emails we may send to you CLICK HERE.

esbconnect owns and maintains the following website and emailing brands: Opt-Me-In, The Goody Bag, Lead Switchboard, WeSearch-UCompare, Your Everyday, Sports Player, One Stop, One Compare UK, Save Compare, Broadstreet Digital, Universal Savings and esbauto. Our privacy policy is the same across all websites and brands we maintain, so you know it is us!

 

Your data will only be on our database if you have consented to receive marketing emails from esbconnect or one of its’ owned websites or mailing brands.

You would have opted in via one of our owned websites or via a partner website. In either case, our opt-in will be present and esbconnect or one it’s mailing brands like The Goody Bag or Opt-Me-In will be listed within their privacy policy ‘as somebody who your personal data may be shared with’. You can always decide to opt-out or choose to not opt-in.

esbconnect is committed to transparency in terms of how we collect and use your “personal data”.

 

“Personal data” is defined in Article 4(1) of the GDPR:

“(1) ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

That’s why we’ve developed this privacy and cookies policy (“Policy”), which:

  • sets out the types of personal data that we collect
  • explains how and why we collect and use your personal data
  • explains when and why we will share personal data within the ESBConnect Group and with other organisations; and
  • explains the rights and choices you have when it comes to your personal data

ESB Connect Limited or one of its’ mailing brand (referred to in this policy as “esbconnect” or “us” or “we”) is the Data Controller as defined by the Data Protection Act 1998. The Data Controller determines the purposes for which and the way any personal data is or will be processed. esbconnect includes any of its associated mailing brands: Your Everyday, ESBAuto, Opt-Me-In, The Goody Bag, WeSearch-UCompare, Sports Player, One Stop, One Compare UK, Hundreds of Brands, Save Compare, Broadstreet Digital and Universal Savings.

 

How We Use Your Personal Data

 

In this Section we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

(c) the legal bases of the processing.

 

What Data is Collected and What Do We Process

 

esbconnect collects both non-personal and personal data on an ongoing basis.

  1. Non-personal data
    Web browser details, operating system data, date and time stamps.
  2. Personal Data
    esbconnect collects 6 types of personal data
    • Internet Protocol (IP) addresses
    • Email address and consent data
    • Demographic data – such as age, gender, home ownership, salary bands and address
    • Behaviour data (“service data”) – such as what you open, click on and transaction categories
    • Device data – the types of device you use – Desktop, phone and tablet data
    • Suppression data – This is where you have unsubscribed from us or a brand. We store this information to ensure we do not re-contact you in the future or from a brand you have chosen not to hear from.

We may process data about your use of the emails we send and visit to our website and services. (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, which emails you open and do not open, which emails you click on and do click on, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website, emails we send and services. The legal basis for this processing is legitimate interests, namely monitoring and improving our website, email sending strategy and services.

We may process your information attached to your email address, for example postcode or gender, “personal data“. The profile data may include your name, address, email address, gender, date of birth, relationship status, interests and hobbies and employment details. The profile data may be processed for delivering you a better service by providing more relevant marketing and advertising offers. The legal basis for this processing is consent. Consent was obtained at the point the email was submitted on our partner websites. At any point you can opt-out by clicking here.

We may process your personal data that is provided in the course of the use of our services (“service data“). The service data may include a record of the types of offers you opened, clicked or transacted on. Information will be aggregated into verticals e.g. clicked on a retail offer. The source of the service data is your engagement with the emails we send. The service data may be processed for the providing our services and to communicate with you in a more effective and relevant manner. The legal basis for this processing is legitimate interest, namely the proper administration of our business.

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is legitimate interest, namely the proper administration of our website and business and communications with users.

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interest, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

Why We Collect Personal Data

 

We collect personal data so that we can target you with offers and content that we believe may be relevant to you. Without profiling you in this manner, we would send you less relevant marketing messages. Profiling may include basic information like your postcode and targeting you with local brands. It could be more detailed, such as your salary banding, so that we can send you relevant products for your income bracket. In general, profiles are grouped into segments to aid targeting rather than by individual targeting.

We do not use data for finance credit checking, medical or religious purposes. We do not store data to identify sexual orientation, political beliefs or religious beliefs.

We do aggregate personal data to develop and improve the content we display to you on the website and send you via email. For example, as there is an increase in mobile usage, our design process has used data to understand device usage.

We do use personal data to detect fraudulent activity on our advertising campaigns. For example, this may include detecting invalid applications for a financial product, or detecting too many clicks from the same source.

We do use your personal data to manage promotions and competitions you enter, to contact you or select you for a promotion.

 

How We Collect Personal Data

 

We collect data in 3 ways

  • Data you enter by forms, either on our websites, partner websites or through an email we send.
  • Browsing data such as views, clicks and transaction history on websites we control
  • Open, click and transaction behaviour on emails we send.

When you register for our Services, you may provide us with:

  • Your personal details, including your postal addresses, email addresses, phone numbers, gender and date of birth and title

When you visit our Websites, or open an email from us:

  • Data about your online purchases (for example, what you have bought, when and where you bought it and how you paid for it)
  • Data about your online browsing behaviour on our Websites and information about when you click on one of our adverts
  • Data about what emails you open, and click on.
  • Data about any devices you have used to access our Services (including the make, model and operating system, IP address, browser type and mobile device identifiers)

To determine whether the data is relevant, we build a profile of you based on the demographic and behaviour data as described above. This allows us to profile your interests and therefore target you with relevant ads or relevant offers and promotions from brands we work with.

You can opt-out at any point. To do this click on the link marked unsubscribe in the email received from us. Your details will be stored on our system only for suppression purposes. And if we receive your email address again, we will automatically remove you from any further communications from us. This suppression method ensures you will never hear from us again. Alternatively, CLICK HERE to request removal from our marketing activity.

Personal Email Data We Receive From Third Parties

esbconnect manages email data on behalf of third parties. Therefore, you may have signed up to receive third party marketing messages via another website or partner, who have then provided us with your details. To do this, you have explicitly opted in for your data to be transferred and used in this manner.

We do the upmost to ensure a valid opt-in exists. The original data controller will provide us with details of the opt-in and then we will audit the opt-in process and the privacy policy. In most cases, we will be named at point of opt-in or you would have opted in to receive marketing messages from certain sectors e.g. charities. If you engage (open/click) on an email from us within the last 365 days, we will continue to mail you. You can opt-out at any point either when you receive an email from us by clicking on the unsubscribe link provided. You can also opt out by CLICKING HERE or request details of where your data was originally obtained from us by going to http://mydetails.opt-me-in.com/

Although we do the upmost to validate that the opt-in to the original list owner is valid and correct, we can only do so much to prove this. In some cases, it may be incorrect and if you believe this to be the case, please do contact us and we will investigate promptly.

Along with the email address, the original source may also supply us with other personal information about you, such as age, gender, postcode. This is used to help us profile you and send you relevant marketing messages. If you wish us to remove this information or update it, please contact us at privacy@esbconnect.com.

The Type of Marketing You Will Receive

We will send you emails which contain marketing messages from brands we work with. The headers and footers within the email will make it clear that we are sending it but the content will be provided by the brand we work with.

The marketing messages you will receive will be relevant to one of the data categories listed below:

Sector Description
Retail
  • Online retail
  • General stores
  • Automotive (including Brochures and Test Drives)
  • Property
  • Food and Drink
  • Technology
  • Home furnishings & Improvements
  • Fashion and clothing
  • Telecoms and utilities
Finance
  • Pensions
  • Loans, credit cards and mortgages
  • Investments & savings
  • Claims Companies
Insurance
  • Home
  • Car
  • Travel
  • Pet
  • Personal and Life
  • Other insurances
Travel
  • Holidays
  • Hotel
  • Airlines
  • Travel booking
Lifestyle
  • Health & Beauty
  • Fitness
  • Charities
  • Media & publishing companies
  • Leisure
  • Gaming
  • Gambling
  • Legal Services
  • Educational institutions
  • Compensation, Legal Services and Personal Injury
  • Injury Compensation Services
  • Careers and Education

Sharing Personal Data Within the esbconnect Group

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal basis set out in this policy.

 

Sharing Personal Data With Other Organisations

We may share personal data with other organisations in the following circumstances:

  • if the law or a public authority says we must share the personal data;
  • if we need to share personal data to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk);
  • to an organisation we sell or transfer (or enter negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the organisation receiving your personal data can use your personal data in the same way as us; or
  • to any other successors in title to our business.
  • to data partners or advertising partners for the purposes of running advertising campaigns. We will only do this where we have obtained explicit consent from the data subject.

We may share your personal data with our third party partners, which may use such personal data for targeted advertising purposes, including for measurement and analytics on campaign performance, personalization, modeling, onboarding, and linkage; such third party partners include zeotap GmbH – for more information regarding zeotap GmbH privacy practices, please see its privacy policy available at: https://www.zeotap.com/privacy_policy. In the event you do not wish your personal data to be shared with zeotap, you may opt-out through the above link.

 

Data Protection – Accessing, Updating, Retaining and Deleting your Personal Data

 

This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain your personal data as follows:

(a) Email address will be retained for a minimum period of 2 years following last click data. We maintain a record of the email address, only to maintain a file of ‘do not mail’. Any data related to the email address e.g. gender, postcode will be deleted 5 years after the last click date.

 

In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of email address will be determined based on the requirements to maintain a suppression file of people who have opted out.

Notwithstanding the other provisions of this privacy policy, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

esbconnect adheres to the Data Protection Act 1998, GDPR and PECR. Under this legislation, you have the right to see the personal data we hold about you. This is called a Subject Access Request.

If you would like a copy of the personal data we hold about you, please go to http://mydetails.opt-me-in.com/

 

Or alternatively write to:

Data Protection Officer, Opt-Me-In, esbconnect, Unit 2 Millars Brook, Molly Millars Lane, Wokingham, RG41 2AD

We want to make sure that the personal data we hold about you is accurate and up to date. If any of the details are incorrect, please let us know and we will amend those details.

 

Your Rights

 

In this Section , we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request this by going to http://mydetails.opt-me-in.com/

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims. We will never erase your email address, so we can maintain a record that we should not mail you

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to mail you.

 

To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. If you wish to withdraw your consent, you can do so by CLICK HERE

 

Data Security

 

esbconnect has appropriate industry standard technology, physical and administrative procedures in place for a company of our size and complexity to protect the data that is collected and stored. Our software is kept up to date with the latest releases to protect against industry known vulnerabilities.

From time to time we may ask other members of our group, or third party service providers, to help us manage our information technology systems. Some of these systems may be located in countries overseas, including countries located outside the European Economic Area (EEA).

We will only transfer your information to a third party service provider or overseas, where we are satisfied that adequate levels of protection are in place to protect the integrity and security of any information being processed and compliance with applicable privacy and data protection laws. These measures may include the use of Standard Contractual Clauses, the EU-US Privacy Shield, Swiss-US Privacy Shield or your consent. You may request further information on the legal security measures used for such transfers via the contact details given in this Privacy Notice.

 

Social Retargeting

Facebook, Snapchat, Instagram, LinkedIn, Google and many other social platforms (marketing partners) offer a service called Custom Audiences. This is where you can upload ‘email addresses’ and target those email addresses with an advert via the platform.

 

We may participate in using the custom audiences function on the platforms mentioned above for the purposes of serving personalised ads based on your interests. This activity is performed by collecting Usage Data and by using cookies and other tracking and data collection methodologies discussed above to transfer information to our marketing partners which manage personalised advertising activities.

Our marketing partners may also use cookies and other tracking and data collection methodologies discussed above to measure advertisement effectiveness and for other purposes that are disclosed in their own privacy policies. We have no access or control over these cookies and other tracking and data collection methodologies that may be used by our marketing partners, and we have no responsibility or liability for the privacy policies and practices of these sites.

AdWords (Google) – We may participate in AdWords program which is a personalized ad service provided by Google Inc. that connects the activity of this site with the Adwords advertising network and the Doubleclick cookie. Information collected: cookie and Usage Data. For the opt-out, visit –> https://support.google.com/ads/answer/2662922?hl=en

Google Analytics for Display Advertising (Google) – We may participate in any and all of the following Google Analytics Advertising Features provided by Google: Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration, and Google Analytics Demographics and Interest Reporting. These features use first party cookies (such as the Google Analytics cookie) for connecting the tracking activity performed by Google Analytics and its cookies with the Adwords advertising network and the DoubleClick cookie (a third-party cookie). Information collected: cookie and Usage Data, including audience data such as age, gender, and interests. For the opt-out, visit –> https://support.google.com/ads/answer/2662922?hl=en You may opt-out of the Google Analytics service with the Google’s Browser Add-on that’s available at –> https://tools.google.com/dlpage/gaoptout

For information in general about Google’s personalised ad campaigns, and specifically about information regarding DoubleClick cookies and how to control and manage Google’s advertising cookies for these campaigns, visit –> http://www.google.com/policies/technologies/ads/

For another Google resource for opting out of Google’s use of cookies, visit –> http://www.google.com/settings/ads

For information regarding how Google uses data when you use Google’s partners’ sites or apps, visit –> http://www.google.com/policies/privacy/partners/

For an additional resource recommended by Google for opting out of a third party vendor’s use of cookies, visit –> http://www.networkadvertising.org/managing/opt_out.asp

Custom Audience (Facebook). We may participate in Facebook.com’s Custom Audience program which enables us to display personalised ads to persons on our email lists when they visit Facebook.com. We provide Personal Information such as your email address and phone number to Facebook to enable Facebook to determine if you are a registered account holder with Facebook. You may opt-out of participation in our Facebook Custom Audience by sending an email, from the email address you are opting out of, to the email address provided in our contact information below. For your opt-out to be effective, you must: (i) place the following text in the subject line of the email – “Opting Out of Facebook.com Website Custom Audience Ads”, and (ii) in the body of the email, include your name and email address. We will forward your name and email address to Facebook.com with a request to delete you from all of our Facebook Custom Audience Ads.

Other Personalized and Behavioural Advertising Services. We may participate in additional retargeting and behavioural advertising services that will be similar to the services described above.

 

Cookies and Similar Technologies

 

We use cookies and similar technologies, such as tags and pixels (“Cookies”) on both our websites and emails we send you. These are used to personalise and improve your customer experience and to provide you with relevant online advertising on websites and via email.

Cookies are small data files that allow us to store settings and identifiers on your desktop computer, laptop or mobile device.

Cookies help us to provide important features and functionality on our Websites and Mobile Apps, and we use them to improve your customer experience. For example, we use Cookies to do the following:

  • Personalise our websites and Mobile Apps for you by remembering your preferences so that you can continue where you left off if you return to a site. This data is stored locally and we do not store this data on our servers.

We also use cookies for Site Abandonment. This is where we place a script on a partner’s website and when you visit their website, our script looks to see if an esbconnect owned cookie exists on your browser. If it exists it triggers an email to be send on the behalf of the advertiser but we will be identified as the data controller and sender. These emails will only be triggered if you have accepted cookies on their site and we have a valid opt-in for you. These will be marketing messages from the owner of that website aimed at improving your interaction with their website.

We may also use cookies for trigger paths, this is where we send a marketing email that has been designated as relevant to individuals that have interacted with an email of ours that you have opened or clicked on.

Deliver Relevant Online Advertising

Cookies help us to deliver online advertising we believe is relevant to you on our Websites, other organisations’ websites and through emails we send you.

Cookies used for this purpose are placed on your device by one of our websites or partner websites, emails we send you or on our Websites by other organisations, and always with your permission. These Cookies store information about your online activity, such as your IP address, the website you arrived from and information about your purchase history or the content of your shopping basket. They may also contain an identifier that links to your email address.

These cookies enable us to control the frequency and the number of times you may see an advert on your different devices. The cookies also help our advertisers identify potential customers who they feel are relevant for their products.

This means that you may see our adverts or adverts from brands we work with on our Websites and on other organisations’ websites. You may also see adverts for other organisations on our Websites.

To help us to deliver online advertising that is relevant to you, we may also combine data we collect through Cookies in the browser of your desktop computer or other devices with other data that we have collected, for example what emails you have opened or the postcode you provided to us or through one of our partners when you opted-in.

 

Measuring the effectiveness of our marketing and advertising

Cookies can tell us if you have seen a specific advert, and how long it has been since you have seen it. This information allows us to measure the effectiveness of our online advertising campaigns and control the number of times you are shown an advert.

We also use Cookies to measure the effectiveness of our marketing communications, for example by telling us if you have opened a marketing email that we have sent you and if this email was advertising a partner, whether you have then clicked through onto the partner’s website and made a purchase.

Cookies we use:

Cookie Purpose
Google Analytics These cookies allow us to collect information about how visitors use the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google
Google Adsense Google uses cookies to serve more relevant ads across the web and limit the number of times a given ad is shown to you. When you visit a website, view an ad, or click an ad supported by Google’s advertising services, Google may set a cookie on your browser. This advertising cookie will appear in your browser as coming from the domain “doubleclick.net”. Learn more about Googles Policies
LiveRamp (Acxiom Limited) LiveRamp cookies allow advertisers to display on the websites you visit, relevant offers based on your consumption habits as well as measure the performance of their advertising campaigns. To work, this service is based on the deposit of a cookie on your browser when opening an email or your visit to the site of one of our partners. They only tell us your encrypted email address in an irreversible way and thus allowing us to create a technical key associated with our cookies. By depositing our cookies some technical information can be automatically collected (such as IP, your operating system or your browser type). Our cookies do not track your navigation. We do not store any information related to

your connection. You can at any time easily oppose the deposit of our cookie by clicking on this link: https://liveramp.uk/cookies-101/.

ESBConnect Limited ESBConnect’s cookies set an identifier linked to your email address this enables us to identify visitors to our advertising clients’ websites and send them a personalised email or serve them personalized ads via display, social, video or mobile. To opt out of ESB Connect Email please CLICK HERE

You can use your browser settings to accept or reject new Cookies and to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or another device. You can find more detailed information about how you can manage Cookies at the All About Cookies and Your Online Choices websites.

 

How to Contact us

If you have any questions, complaints or suggestions regarding this policy or our data practices, please email, call or mail us:

email: data@esbconnect.com
tel: +44(0)118 979 4055
mail: ESBConnect Ltd, The Cursitor Building, 38 Chancery Ln, London, WC2A 1EN

 

Changes to this Privacy Policy

ESB Connect will occasionally update this privacy policy. When we do, we will also revise the last updated date.

Last update: 16/05/2018