IrvinGQ PRIVACY NOTICE
For the purpose of UK data protection laws, the data controller is IrvinGQ, Llangeinor, Bridgend, CF32 8PL.
2. POLICY STATEMENT
IrvinGQ is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured it will only be used in accordance with this privacy statement.
IrvinGQ may change this policy from time to time by updating this page. You should check this page from time to time to ensure you are happy with any changes. This policy is effective from 24 May 2018.
This Notice has been developed to describe how we handle personal information collected from individuals working for our clients, individual suppliers and individuals working for corporate supplier, persons who use the Airborne website, or who, following an invitation from Airborne in the course of any marketing and/or event communication processes, such as in – person, email, telephone, text messaging direct mail and online, provide personal information to IrvinGQ.
3. PERSONAL AND SENSITIVE PERSONAL DATA
Personal information means any information relating to an identified or identifiable natural person; an identifiable person is one who can be directly or indirectly identified by reference to an identifier such as name, an identification number, location data, online identifier or to one or more factors specific to that person.
Sensitive personal information is a subset of personal information and is generally defined as any information related to racial /ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, or other medical information including biometric and genetic data, or sexual life preferences. In some instances, sensitive personal information may also include criminal allegations or convictions.
4. HOW WE OBTAIN PERSONAL DATA
When you visit the IrvinGQ website we collect personal information about your visit. Our web server automatically records details about your visit (for example, your IP address, the type of browser used, the IrvinGQ website pages that you visit and the duration of your visit).
We, by using a tracking code from a third party provider, also collect information on the public IP address of the requesting computer. This tool provides us with information as to the company that has visited our website(s), but individuals cannot be identified by this tool.
In addition, we collect the personal details which you provide online, for example, when you enter personal details (e.g. name, address, email address, phone number) on our website contact page.
We also collect personal information directly from you in the course of sales or purchasing activities and/or in connection with marketing events, for instance: business cards; personal contact details; emails and other social media.
In some circumstances we may collect personal information about you from third parties, such as your employer, or professional organisations to which you belong, or personal information that you have placed in the public domain, such as from Facebook or LinkedIn.
By providing your personal information as described above, or by proceeding with your visit to IrvinGQ websites, you are accepting and consenting to the practices described in this Privacy Notice, and you agree to the transfer, storing or processing of your personal information in the manner described in this Notice.
If you subsequently wish to withdraw your consent to the collection and handling of your personal information, then you may follow the instructions on any communications you receive from us or contact the Data Protection Officer at DPO@irvingq.com
Generally, we do not collect sensitive personal data about our business contacts, save and unless you provide such information to us, for example, limited medical information to facilitate your attendance at an event or a visit to our premises.
5. LINKS TO OTHER WEBSITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Cookies are small files of letters and numbers. These files are either stored in the memory of your computer or other device such as mobile phones or are placed on the hard drive of your device.
7. USES MADE OF THE INFORMATION COLLECTED AND PROVIDED TO US
We will use this information for:
- We may use your contact information and preferences to send you newsletters that we may circulate from time to time, news about any events we are organising or participating in, information about us, the products and/or services that IrvinGQ or companies within our Group provide, and/or to respond to any user enquiries.
- If specific personal information is necessary to supply a particular service (e.g. an e-mail address for electronic news updates) then this service is only available to those users who provide this information. It does affect a user’s ability to use other parts of the site.
- We use full contact details to create a profile of our users. A ‘profile’ is stored information we keep on individual users that details their viewing preferences. This profile is used to tailor a user’s visit to our site, to improve the content of the site for the user and to direct pertinent marketing promotions to them.
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- As part of our efforts to keep our site safe and secure;
- To allow you to participate in interactive features of our service, when you choose to do so;
- To make suggestions and provide information to you and other users of our site about us and the products and/or services we and other Airborne System Group companies provide.
- We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the information we receive).
- We will only collect and handle your personal information in accordance with your contact preferences. You can also subsequently inform us of your contact preferences, including any request to withdraw your consent to the collection and handling of your personal information by contacting:
The Data Protection Officer, IrvinGQ, Llangeinor, Bridgend, CF32 8PL DPO@irvingq.com
8. SHARING INFORMATION
Although we make every effort to preserve user privacy, we may need to disclose personal information when required by law, including (without limitation) in order to comply with applicable local laws or judicial proceedings, court orders or any other legal processes.
Your information may be shared under contractual control with other companies who collect and handle personal information on our behalf. For these purposes information may be transferred to other companies located outside the European Economic Area. Any personal information that is transferred will be protected accordance with applicable laws. When we transfer personal information from the European Economic Area to other countries in which applicable laws do not offer the same level of data privacy protection as GDPR, we take measures to provide an appropriate level of data privacy protection.
In some circumstances personal information may be shared with third parties for legal reasons, such as:
- To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities; or
- In the event of a merger , sale, restructure , acquisition joint venture, assignment, transfer or other disposition of all or any portion of IrvinGQ business assets
9. STORING INFORMATION
IrvinGQ is part of a global organisation, and personal information may be stored and processed outside of the European Economic Area. We take steps to ensure that information we collect is processed according to this Privacy Notice, the requirements of GDPR and other applicable laws.
10. RETAINING INFORMATION
IrvinGQ may be required to use and retain information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate:
- under applicable law;
- to respond to requests from courts, law enforcement agencies, regulatory agencies and other public and government authorities;
- to enforce a contract; or
- to protect our rights, privacy, safety or property or those of other persons
11. DATA SECURITY
We have physical, electronic and administrative security processes in place in our facilities to protect against the loss, misuse, unauthorized access, or alteration of information. Our company uses secure encryption technology (secure socket connection) for all sensitive and financial personal information transmitted on our site.
Despite this, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to our site; any transmission is at your own risk. We do not accept liability for any interception of your personal information that may occur.
12. YOUR RIGHTS
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:-
- To access the information we hold about you free-of-charge, together with various information about why and how we are using your information, to whom we may have disclosed that information, from where we originally obtained the information and for how long we will use your information.
- To ask us to rectify any information we hold about you that is inaccurate or incomplete.
- To ask us to erase the information we hold about you (the ‘right to be forgotten’). Please note that this right can only be exercised in certain circumstances and, if you ask us to erase your information and we are unable to do so, we will explain the reason why.
- To ask us to stop using your information where:-
- the information we hold about you is inaccurate;
- we are unlawfully using your information;
- we no longer need to use the information; or
- we do not have a legitimate reason to use the information. Please note that we may continue to store your information, or use your information for the purpose of legal proceedings or for protecting the rights of any other person.
- To ask us to transmit the information we hold about you to another person or company in a structured, commonly-used and machine-readable format. Please note that this right can only be exercised in certain circumstances and, if you ask us to transmit your information and we are unable to do so, we will explain why not.
- Where we use/store your information because it is necessary for our legitimate business interests, to object to us using/storing your information. We will stop using/storing your information unless we can demonstrate why we believe we have a legitimate business interest which is more important than your interests, rights and freedoms.
- Where we use/store your data because you have given us your specific, informed and unambiguous consent, you may withdraw your consent at any time.
- To object to us using/storing your information for direct marketing purposes.
- If you wish to exercise any of your legal rights, please contact our Data Protection Officer by writing to the address at the top of this policy, or by emailing us at DPO@irvingq.com
- You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.
13. OPTING OUT OF RECEIVING MARKETING COMMUNICATIONS
You can ask us to stop sending you marketing communications at any time by contacting our Marketing Manager, Jessica Cook, by writing to the address at the top of this policy, or by emailing us at email@example.com
If you have any queries in relation to this policy, please write to our data protection officer at the address above or email DPO@irvingq.com
DATA PROTECTION PRIVACY NOTICE FOR EMPLOYEES AND PROSPECTIVE EMPLOYEES
1. WHAT IS THE PURPOSE OF THIS DOCUMENT?
IrvinGQ (IrvinGQ/We) is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with all Data Protection Legislation.
It applies to all employees, workers and contractors.
IrvinGQ is the “data controller” of personal data of employees and candidates for employees. This means we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This notice applies to current and former employees, workers, contractors and consultants. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. A copy of this notice can be located on the ‘I’ Drive, Q Pulse, Company notice boards and on the Company’s Website www.irvingq.com.
2. DATA PROTECTION PRINCIPLES
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
- Not transferred to another country without appropriate safeguards.
- Allow you to exercise your legal rights in relation to personal data.
3. THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data, which require a higher level of protection.
We may collect, store, and use the following categories of personal information about you:
- Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
- Date of birth.
- National Insurance Number.
- Marital status and dependants.
- Next of kin and emergency contact information.
- Passport and Visa information and other documentation that verifies your entitlement to work in the UK.
- National Insurance number.
- Bank account details, payroll records and tax status information.
- Salary, annual leave, pension and benefits information.
- Start date.
- Location of employment or workplace.
- Copy of driving licence.
- Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
- Employment records (including job titles, work history, working hours, training records and professional memberships).
- Compensation history.
- Performance information.
- Disciplinary and grievance information.
- Information about your use of our information and communications systems.
- Holiday records.
- Certificates received in relation to security vetting.
- Clocking and timekeeping records.
- We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
- Information about your health, including any medical condition, health and sickness records.
- Information received from DBS checks about criminal convictions and offences.
- Trade Union Membership solely for “check off” purposes.
4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We typically collect personal information about employees, workers and contactors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies.
We will collect additional personal information in the course of job-related activities throughout the period of you working for us.
5. HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
Where we need to perform the contract we have entered into with you.
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
- Where it is needed in the public interest, for official purposes or to comply with the regulatory obligations imposed on us.
6. SITUATIONS IN WHICH WE WILL USE YOUR PERSONAL INFORMATION
We need all the categories of information in the list above (see The kind of information we hold about you) primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below. We have indicated the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.
- Making a decision about your recruitment or appointment.
- Determining the terms on which you work for us.
- Checking you are legally entitled to work in the UK.
- Paying you and, if you are an employee, deducting tax and National Insurance contributions.
- Providing life assurance, medical insurance and/or pension benefits.
- Liaising with your pension provider.
- Administering the contract we have entered into with you.
- Business management and planning, including accounting and auditing.
- At your request to provide information to a mortgage provider or other loan provider.
- Conducting performance reviews, managing performance and determining performance requirements.
- Making decisions about salary reviews and compensation.
- Assessing qualifications for a particular job or task, including decisions about promotions.
- Gathering evidence for possible grievance or disciplinary hearings.
- Making decisions about your continued employment or engagement.
- Making arrangements for the termination of our working relationship.
- Education, training and development requirements.
- Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work.
- Ascertaining your fitness to work.
- Managing sickness absence.
- Complying with health and safety obligations.
- Identifying any “reasonable adjustments” to assist with illness and disabilities.
- To prevent fraud.
- To monitor your use of our information and communication systems to ensure compliance with our IT policies.
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
- To conduct data analytics studies to review and better understand employee retention and attrition rates.
- Equal opportunities monitoring.
- To administer deductions required by the Child Support Agency or court order.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
We reserve the right to monitor telephone, computer, mobile telephone and internet use, as detailed in our Computer/Internet/E-mail – Acceptance of Use and Expenses Policies to ensure compliance with Company rules and policies. If non-compliance with Company policy is identified, information identified may be processed as part of a disciplinary investigation.
CCTV is in use in our buildings. How that data is used and processed is set out in our CCTV Policy.
8. IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
9. CHANGE OF PURPOSE
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that it is required for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
10. HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
In limited circumstances, with your explicit written consent.
- Where we need to carry out our legal obligations and in line with our data protection policy.
- Where it is needed in the public interest, such as for equal opportunities monitoring, and in line with our data protection policy.
- Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.
- Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about employees or former employees in the course of legitimate business activities with the appropriate safeguards.
11. OUR OBLIGATIONS AS AN EMPLOYER
We will use your particularly sensitive personal information in the following ways:
- We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.
- We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
12. DO WE NEED YOUR CONSENT?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
13. INFORMATION ABOUT CRIMINAL CONVICTIONS
We may only use information relating to criminal convictions where the law allows us to do so.
Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We may also process such information about employees or former employees in the course of legitimate business activities with the appropriate safeguards.
14. AUTOMATED DECISION-MAKING
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
Where we have notified you of the decision and given you 21 days to request a reconsideration.
Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
15. DATA SHARING
We may have to share your data with third parties, including third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We may transfer your personal information outside the EU where we have either your explicit consent or there is a lawful basis to do so.
If we do, you can expect a similar degree of protection in respect of your personal information.
16. WHY MIGHT YOU SHARE MY PERSONAL INFORMATION WITH THIRD PARTIES?
We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
17. WHICH THIRD-PARTY SERVICE PROVIDERS PROCESS MY PERSONAL INFORMATION?
”Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following activities are carried out by third-party service providers: pension administration, payroll software provider, HR information systems provider, benefits and insurance providers, occupational health providers, and IT service providers.
18. HOW SECURE IS MY INFORMATION WITH THIRD-PARTY SERVICE PROVIDERS AND OTHER ENTITIES IN OUR GROUP?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
19. WHAT ABOUT OTHER THIRD PARTIES?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.
We may also need to share your personal information with a regulator or to otherwise comply with the law.
20. TRANSFERRING INFORMATION OUTSIDE THE EU
We may transfer the personal information we collect about you to our parent company, TransDigm Group Incorporated in the USA. There is not an adequacy decision by the European Commission in respect of the USA. This means that the USA to which we transfer your data is deemed not to provide an adequate level of protection for your personal information.
The company undertakes to take all appropriate guarantees, either on the basis of an adequacy decision such as that for the Privacy Shield, or, in the absence of such a decision, on the basis of appropriate guarantees, in particular those drawn up on the model of standard contractual clauses made public by the European Commission. A copy of the Company’s agreement with TransDigm Group Incorporated which may be requested at the following e-mail address DPO@rirvingq.com
21. DATA SECURITY
We have put in place measures to protect the security of your information. Details of these measures are available upon request. Any hard copy documents are stored in a locked cabinet only accessible by the HR team. Electronic documents are stored on a restricted drive and/or software packages only accessible by the HR team.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
22. DATA RETENTION
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the Human Resources Team. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy.
23. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Controller Officer in writing.
24. NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
25. WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
26. RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the HR Department. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
27. CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.