Privacy Policy

PACCOR Group (“PACCOR”, “we”, “us”, and “our”) takes your privacy seriously. Please read this Privacy Policy, which describes the types of information we collect through www.paccor.com (the “Website”), and how we use that information.

Effective Date: July 15th, 2020

A. Overview

This Privacy Policy is incorporated into, and subject to, the terms of the Website Terms of Use. This Privacy Policy covers PACCOR’s treatment of personally identifiable information (“Personal Information”) and other non-personally identifiable information that we gather when you access the Website and when you order products or register to receive services from the Website. By visiting the Website and ordering products or services through it, you expressly acknowledge that you accept the practices and policies outlined in this Privacy Policy and consent to our use and disclosure of your Personal Information in the manner described in this Privacy Policy.

If you do not agree to the terms of this Privacy Policy, please do not use the Website. If you have questions regarding this Privacy Policy, you may contact us via the form available at https://www.paccor.com/contact.

B. Information we collect

If you choose to use the Website to order products or services, we may require you to provide contact and identity information, payment information, and other information. The information that we gather from you through the Website enables us to provide, maintain and improve the Website, personalize your experience, process your requests, and process the requests of others, and includes the following information:

Personal Information that you provide to us or otherwise disclose or post in connection with the Website, which may include the following:

  • Your name, address, country, phone number, email address, mobile device information, and credit card information and preferences;
  • Any information that you make public, including photographs, videos, and other content; and
  • Communications and other messages, including correspondence between Paccor and you.

Non-personally identifiable information that we gather on the Website, including your IP address, computer sign-on data, statistics on page views, traffic to and from the Website and individual pages on the Website, and data that we may collect through cookies or other means. You can take steps to disable cookies on your browser; however, this may affect your ability to use the Website. Please see our Cookie Policy for more information on our use of cookies.

C. OUR USE AND DISCLOSURE OF YOUR INFORMATION

We may use your personal information to: provide you with products and services; resolve disputes, calculate and collect fees and troubleshoot problems; verify users’ identity and the information users provide; encourage a safe online experience and enforce our policies; customize the Website, analyze usage of the Website, improve and measure interest in our products and services and inform users about products and services; provide users with information that may affect their use of the Website and our products and services; communicate marketing and promotional offers; provide customer service; and perform other business activities. During the course of our business, we may use your Personal Information to deliver information to you that is targeted to your interests. If you do not want to receive email or other communications from us or if you would like us to remove you from our database, please let us know by sending an email to us via the form available at https://www.paccor.com/contact

If you order products or services through the Website, you may receive certain communications from PACCOR, such as administrative announcements and customer service messages, and you will not be able to opt out of receiving such communications. From time to time, we may implement solutions designed to more efficiently capture your communications preferences. In any such event, we will strive to reflect any previously stated communicated preferences within such solutions. We may share, and you hereby consent to our sharing, Personal Information with the following: Corporate affiliates to help coordinate providing our products and services. Service providers and others who help with our business operations and assist in the delivery of our products and services. Examples include, but are not limited to, the following: maintaining servers, sending email, removing repetitive information from user lists, analyzing data, providing marketing assistance, processing payments, reviewing content, providing customer service, and transporting and delivering products. Third parties if we believe that disclosure is advisable or necessary to comply with the law, to enforce or apply our conditions of use and other agreements, or to protect the rights, property, or safety of PACCOR, our employees, our users or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction. Entities who acquire us, or assets from us. In some cases, we may choose to buy or sell assets. In these types of transactions, user information, including your Personal Information, is typically one of the business assets that are transferred.

Moreover, if PACCOR, all or our assets or the Website were acquired, or in the unlikely event that PACCORgoes out of business or enters bankruptcy, user information, including your Personal Information, would be one of the assets that is transferred to or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of PACCOR, our assets or the Website may continue to use your Personal Information as set forth in this Privacy Policy. Persons or entities with whom you consent to have your Personal Information shared. For instance, when you request information, services or products from us, from our affiliates or a third party through us, or when you post information to the Website, you provide your consent for us to share that information with others. Please note that whenever you post information on or through the Website, you are giving us your consent to share that information with third parties. Payment Processors. If you purchase products through the Website, payment information may be collected by a third party payment processor. Note that each third-party payment processor collects and shares your information according to its own privacy policy and terms of service. We encourage you to become familiar with such policies and terms.

D. Third party websites

Emails from PACCORor its business partners, and the Website itself, may contain links to other Internet websites, including sites that may or may not be owned or operated by PACCOR. The Website may also link to or incorporate third party websites or services to fulfill orders, process payments and provide other services. Unless otherwise explicitly stated, we are not responsible for the privacy practices or the content of such websites, including such sites’ use of any information collected when email recipients or the Website’s visitors click through links to those sites or use services provide by them through the Website. If you visit such websites or use services provide by them through the Website, we encourage you to become familiar with the privacy practices and any terms of use of such sites.

E. ACCESSING, REVIEWING AND CHANGING YOUR PERSONAL INFORMATION

You may access, review and change information in your account at any time. You may contact us via the form available at https://www.paccor.com/contact after choosing your country to review any Personal Information we store about you that is not available on the Website.

We may delete Personal Information when we no longer need it for the purposes described herein. However, any information that you have made public may continue to be displayed unless you remove it. Additionally, we retain Personal Information as permitted by law to resolve disputes and enforce our policies.

F. Security

If you have a password-protected account on the Website, it is your responsibility to keep your account and Personal Information safe and secure by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.

To prevent unauthorized access, promote data security, and encourage appropriate use of information, we use a variety of tools to assist in the protection of your information. You should note, however, that “perfect security” does not exist on the Internet. Third parties may unlawfully intercept or access transmissions or private communications. You should not expect that your Personal Information will remain private.

G. Security

PACCOR is concerned about the safety and privacy of children who use the Internet and we will never knowingly request Personal Information from anyone less than 13 years of age without prior verifiable parental consent. If you become aware that your child under 13 years of age has provided us with Personal Information without prior verifiable parental consent, please contact us via the form available at  https://www.paccor.com/contact and we will use our best efforts to promptly remove such information from our files.

H. Notification of changes

We may amend this Privacy Policy at any time by posting the amended terms on the Website. In the event of amendment, all terms shall become effective immediately upon posting to the Website.

I. Questions or concerns

If you have any questions or concerns regarding privacy at the Website, please send a detailed message via the form available at https://www.paccor.com/contact. We will make every effort to resolve your concerns.

Our postal address is:
PACCOR Packaging GmbH 
Peter-Müller-Str. 16/16a
40468 Düsseldorf
Germany

FOR VISITORS FROM THE EEA

We respect the privacy of every person who visits or registers with www.paccor.com (the “Site”) and who uses the services that we make available from the Site or who engages with us to purchase products or services (be it through the Site or not) (our “Services”) and we are committed to ensuring a safe online experience.

1. Purpose of this policy

This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out how we process personal data in relation to any third party who assists us in providing the Site or the Services. This Privacy Policy also sets out your rights in respect of our processing of your personal information.

This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Legal notice.

2. Who are we and what do we do?

The Site and our Services are operated by PACCOR Packaging GmbH (“we”, “us” or “our”).

PACCOR Packaging GmbH is the data controller responsible for your personal information processed via the Site.

PACCOR Packaging GmbH established and existing under the laws of Germany, with registered office at Peter-Müller-Str. 16/16a, 40468 Düsseldorf, Germany and registered with the Düsseldorf Company Register under number HRB 82819.

Please note that depending on from which country you access the Site or with which PACCOR entity you contract in relation to the Services the following entities may also be data controllers responsible for your personal information processed in relation to the Services:

  • PACCOR Packaging GmbH
  • PACCOR Deutschland GmbH
  • PACCOR (Ravensburg) Deutschland GmbH
  • PACCOR Polska Sp. z o.o.
  • PACCOR Polska Sp. z o.o. Skiemiewice Branch
  • PACCOR Lietuva UAB
  • PACCOR Ukraine LLC
  • PACCOR Serbia d.o.o.
  • PACCOR Romania S.R.L.
  • PACCOR Hungary Kft
  • PACCOR Netherlands B.V.
  • PACCOR Bulgaria JSC
  • PACCOR (Mansfield) UK Limited
  • PACCOR UK Limited
  • PACCOR Finland Oy
  • PACCOR France SAS
  • PACCOR Turkey Ambalaj Sanayi A.Ṣ.
  • PACCOR NA, Inc.
  • PACCOR Iberia S.A.
  • PACCOR Singapore Pte Limited
  • PACCOR Packaging NA, Inc.

 

How to contact us?

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by sending an e-mail to  ISO@paccor.com .
If you are accessing the Site from Germany or you are being provided Services in Germany, please note that the PACCOR German entities have a Data Protection Officer whose details are as follows DPO@paccor.com.

3. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our products and services and develop and market new products and services; (iii) carry out requests made by you on the Site; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you or third parties; (vii) protect the rights, property or safety of us or third parties, including our other customers and users of the Site; (viii) provide support for the provision of our Services; and (ix) use it as otherwise required or permitted by law.

To undertake these goals we normally process the following personal information:

  • Name, job title and company name.
  • Contact information including email address.
  • Demographic information such as postcode, preferences and interests.
  • Other information relevant to provision of services.

In particular, we use your personal information for the following purposes:

 

FULFILMENT OF PRODUCTS AND SERVICES

We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or in relation to provision of the Services. We use the contact details you have provided to us so that we can respond to requests for information, fulfil the supply of products and services you have ordered from us, or when providing Services.
 

Who do we share your personal information with for this purpose?

We may share your personal information with the following categories of third parties:

  • Systems and service providers that assist us in updating or maintaining our customer relationship management system or marketing efforts; and
  • Consultants that advise us on our product and marketing initiatives.
     
What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we can undertake any Services administration necessary.

 

CUSTOMER SERVICES

Our Site uses various user interfaces to allow you to request information about our products and services: these include printed and electronic inquiry forms. Contact information may be requested in each case, together with details of other personal information that is relevant to your customer service inquiry. This information is used in order to enable us to respond to your requests.
 

Who do we share your personal information with for this purpose?

We do not share your personal information for this purpose.
 

Your feedback about our products and services

From time to we will contact you to invite you to provide feedback about our products and services in the form of online or postal surveys. We use this information to help us improve the quality of service provided by our staff. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.

 

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH FOR THESE PURPOSES?

We use a third party service provider to assist us with customer surveys and feedback requests.

Should our third party provider be located in the USA, their use of your personal information would be governed by EU Model Contracts.

What is our legal basis?

It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

 

BUSINESS ADMINISTRATION AND LEGAL COMPLIANCE. 

We use your personal information for the following business administration and legal compliance purposes:

  • to comply with our legal obligations(including any Know Your Client or Anti-Money Laundering or Anti-Bribery obligations or Export Control and Trade Sanctions restrictions);
  • to enforce our legal rights;
  • to undertake any administrative tasks in relation to any third parties who help us provide the Site or the Services to customers (and similar);
  • to protect rights of third parties; and
  • in connection with a business transition such as a supply deal with a third party company or a merger, or acquisition by another company, or sale of all or a portion of our assets.
Who do we share your personal information with for these purposes?

We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities. We also share your data with a third party software provider, which hosts a data base of entities and individuals restricted under trade sanctions laws of the countries in which we operate. Should our third party provider being located in the USA, their use of your personal information would be governed by EU Model Contracts.
 

 What is our legal basis?

Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
Where we share your sensitive personal information, we shall obtain your consent to do so.

 

CUSTOMER INSIGHT AND ANALYSIS

We analyze your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services such as the products and services you have purchased or viewed.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following:

  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site;
  • information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.

Our web pages and e-mails contain “cookies” “web beacons” or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf.

Please see our cookie policy for further information.

This information is used to create profiles and insights about your shopping habits and the shopping habits of our other customers. Where we have your consent to do so, we will also use your location data for customer insight purposes.

By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of offers our registered users like to see.

We also use this information to help us with the selection of future product and service lines, and website design and to remember your shopping preferences.

We also use this information for marketing purposes (see the marketing section below for further details).

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party service providers to assist us with customer insight analytics. These providers are described in our Cookie Policy.
Should our third party provider being located in the USA, their use of your personal information would be governed by EU Model Contracts.

 

MARKETING COMMUNICATIONS

We carry out the following marketing activities using your personal information:

 

POSTAL MARKETING

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it             is collected) and/or your address details, to send you marketing communications by post.

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.
 

What is our legal basis?

Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

 

EMAIL MARKETING

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you.
 

What is our legal basis?

Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

 

SOCIAL MEDIA MARKETING

We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalized advertising on social media channels operated by LinkedIn, Twitter, YouTube, Facebook and/or Google where you are a registered user of such services.
We do this using Facebook Customer Audiences and/or Google Customer Match respectively. Please note that such activity is also subject to the privacy choices you have elected to make on such services.

Who do we share your personal information with for these purposes?

We share your email address with third party service providers who assist us with social media remarketing campaigns.

Your encrypted email address is also shared by us or our third party service providers with Facebook and/or Google under the terms of their Facebook Customer Audiences and/or Google Customer Match services respectively.
 

What is our legal basis?

Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We do not engage in social media remarketing.

 

SOCIAL MEDIA INSIGHT

Where you are a registered user of Facebook, or of a Google service, we will use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services that share similar interests to you based on:

  • information that we observe about you from your interactions with our Site, our email communications to you and/or Services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected); and
  • the information Facebook and/or Google hold about you.

We do this using Facebook Lookalike Audiences and/or Google Similar Audience respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services.
 

Who do we share your personal information with for these purposes?

We share your email address with third party service providers who assist us with social media remarketing campaigns.

Your encrypted email address is also shared by us or our third party marketing consultancies with Facebook and/or Google under the terms of their Facebook Customer Audiences and/or Google Customer Match respectively.

What is our legal basis?

Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

4. HOW DO WE OBTAIN YOUR CONSENT?

Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or
  • by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy.

5. OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES

Our Site use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

6. THIRD PARTY CONTRACTORS

We may appoint sub-contractor data processors as required to deliver the Services, such as, without limitation, website developers, hosting companies and advertising agencies who will process personal information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place necessary contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.

7. EXTRA-EEA TRANSFERS

If you are based within the EEA, please note that where necessary to deliver the Services we will transfer personal information to countries outside the EEA (including to other Paccor Group companies). When doing so we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

8. THIRD PARTY LINKS AND SERVICES

Our Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Policy no longer applies. 

Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party website and third party service providers.

9. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We will retain your personal information in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world) (or for longer as we are required to do so according to our regulatory obligations). We may then destroy such files without further notice or liability to you. If you request your files and documents we may charge you for the costs of copying a duplicate.

If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.

10. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. 

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

11. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?

You have the following rights in relation to the personal information we hold about you:

Your right of access

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
 

Your right to rectification

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
 

Your right to erasure

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
 

Your right to restrict processing

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
 

Your right to data portability

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
 

Your right to object

You can ask us to stop processing your personal information, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal information for direct marketing.
     
Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
 

Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
 

Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to your national Data Protection Authority whose contact details are available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

12. CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy from time to time

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.