TERMS OF USE
PLEASE READ THESE TERMS OF USE CAREFULLY
BY TICKING THE “AGREE TO TERMS” BOX ON REGISTERING TO USE THE SERVICE YOU AGREE TO THESE TERMS WHICH WILL BIND YOU.
WHO WE ARE AND WHAT THIS AGREEMENT DOES
We “Ping Services Limited” license you to use:
Chapter Service App, or Web Platform, the data supplied with the software, and any updates or supplements to it.
Any related online documentation we provide (Documentation).
The service you connect to via the App and the content we provide to you through it (Service).
as permitted in these terms.
YOUR PRIVACY
Under data protection legislation, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes and your rights in relation to your personal data and how to exercise them. This information is provided in our fair processing notice below and it is important that you read that information.
Please be aware that internet transmissions are never completely private or secure and that any message or information you send using the App or any Service may be read or intercepted by others, even if there is a special notice that a particular transmission is encrypted.
TERMS OF APP STORE OR GOOGLE PLAY ALSO APPLY
The ways in which you can use the App and Documentation may also be controlled by the Apple App Store’s and/or Google Play’s rules and policies. Those rules and policies will apply instead of these terms where there are differences between the two. Their rules and policies can be found here: https://policies.google.com/privacy.
HOSTING PROVIDERS
The App and Service are hosted by Digital Ocean and Amazon AWS (back up). The ways in which you can use the App and Service are also controlled by their terms of service, which will apply instead of these terms where there are differences between the two. Their terms of service can be found here:
SUPPORT FOR THE APP AND HOW TO TELL US ABOUT PROBLEMS
Support. If you want to learn more about the App or the Service or have any problems using them please email us at [email protected].
Contacting us (including with complaints). If you think the App or the Services are faulty or misdescribed or wish to contact us for any other reason please email our customer service team at [email protected] or call them on 0203 3688454.
How we will communicate with you. If we have to contact you, we will do so by email, by SMS or by pre-paid post, using the contact details you have provided to us.
HOW YOU MAY USE THE APP
In return for your agreeing to comply with these terms you may:
download a copy of the App onto one or more of your mobile or handheld devices and view, use and display the App and the Service on such devices for your personal purposes only.
use any Documentation we provide to support your permitted use of the App and the Service.
receive and use any free supplementary software code or update of the App incorporating “patches” and corrections of errors as we may provide to you.
You must not allow anyone else to use the App. You must not share the App with any other person, nor allow any other person to use it.
YOU MUST BE 18 TO ACCEPT THESE TERMS AND USE THE APP
You must be 18 or over to accept these terms and use the App.
YOU MUST BE INVITED BY US TO USE THE SERVICE
You must be personally invited by us to use the App and Service. Invitations are only provided to residents of [property name] or to certain non-residents at our complete discretion. Our personal invitation will be made by email and is an invitation to treat only: it is not an offer to provide the Service. By accepting our invitation, you are offering to receive the Service subject to these terms. We accept that offer by providing you with a temporary password in order that you can register with the Service. We are not obliged to invite anyone to use the Service and we can withdraw our invitation at any time.
YOU MUST KEEP YOUR PASSWORD CONFIDENTIAL
If you are accepted to use the Service, you will receive a temporary password which will allow you access to the App and to your account. You can change your password in your account and manage your personal profile. You must keep your password confidential and you must not share or disclose it to anyone else. If you suspect your password has been compromised, you should change it as soon as possible, and let us know.
YOU MAY NOT TRANSFER THE APP TO SOMEONE ELSE
We are giving you personally the right to use the App and the Service as set out above. You may not otherwise transfer the App or the Service to someone else, whether for money, for anything else or for free. If you sell, transfer or dispose of any device on which the App is installed, you must remove the App from it.
CHANGES TO THESE TERMS
We may need to change these terms to reflect changes in law or best practice or to deal with additional features which we introduce. We will notify you of a change when you next start the App. If you do not accept the notified changes you will not be permitted to continue to use the App and the Service.
UPDATE TO THE APP AND CHANGES TO THE SERVICE
From time to time we may automatically update the App and change the Service to improve performance, enhance functionality, reflect changes to the operating system or address security issues. Alternatively, we may ask you to update the App for these reasons.
If you choose not to install such updates or if you opt out of automatic updates you may not be able to continue using the App and the Service.
IF SOMEONE ELSE OWNS THE PHONE OR DEVICE YOU ARE USING
If you download the App onto any phone or other device not owned by you, you must have the owner’s permission to do so. You will be responsible for complying with these terms, whether or not you own the phone or other device. You must only download the App onto a phone or other device that you personally control and use, even if it is not owned by you.
WE MAY COLLECT TECHNICAL DATA ABOUT YOUR DEVICE
By using the App or any of the Services, you agree to us collecting and using technical information about the devices you use the App on and related software, hardware and peripherals to improve our products/services and to provide any Services to you.
WE ARE NOT RESPONSIBLE FOR OTHER WEBSITES OR SERVICES YOU LINK TO
The App or any Service may contain links to, or permit communication with, other independent websites or providers of services or products which are not provided by us. Such independent sites or providers are not under our control, and we are not responsible for and have not checked and approved their content, services, products or their privacy policies (if any).
You will need to make your own independent judgement about whether to use any such independent sites or providers of products or services, including whether to buy any products or services offered by them. By including links or permitting communication through the App to third parties, we do not recommend or endorse their products or services. We will not be liable for any loss or damage that may arise from your use of them.
LICENCE RESTRICTIONS
You agree that you will:
not rent, lease, sub-license, loan, provide, or otherwise make available, the App or the Services in any form, in whole or in part to any person without prior written consent from us;
not copy the App, Documentation or Services, except as part of the normal use of the App or where it is necessary for the purpose of back-up or operational security;
not translate, merge, adapt, vary, alter or modify, the whole or any part of the App, Documentation or Services nor permit the App or the Services or any part of them to be combined with, or become incorporated in, any other programs, except as necessary to use the App and the Services on devices as permitted in these terms;
not disassemble, de-compile, reverse engineer or create derivative works based on the whole or any part of the App or the Services nor attempt to do any such things, except to the extent permitted by law;
not access all or any part of the App or Services in order to build a product or service which competes with the App or Services;
not use the App or Services to provide services to third parties, except as expressly permitted by us; or
comply with all applicable technology control or export laws and regulations that apply to the technology used or supported by the App or any Service.
ACCEPTABLE USE RESTRICTIONS
You must:
not use the App or any Service in any unlawful manner, for any unlawful purpose, or in any manner inconsistent with these terms, or act fraudulently or maliciously, for example, by hacking into or inserting malicious code, viruses, malware or harmful data, into the App, any Service or any operating system or by doing anything which may prevent, impair or otherwise adversely affect the operation of the App, Service or any operating system;
not infringe our intellectual property rights or those of any third party in relation to your use of the App or any Service, including by the submission of any material (to the extent that such use is not licensed by these terms);
not transmit any material that is defamatory, offensive or otherwise objectionable in relation to your use of the App or any Service;
not transmit any material or use the App or Service in any way which may be threatening, menacing, harassing, blasphemous, or liable to incite racial hatred or discriminate in any way;
not use the App or any Service in a way that could damage, disable, overburden, impair or compromise our systems or security or interfere with other users; and
not collect or harvest any information or data from any Service or our systems or attempt to decipher any transmissions to or from the servers running any Service.
INTELLECTUAL PROPERTY RIGHTS
All intellectual property rights in the App, the Documentation and the Services throughout the world belong to us and our licensors and the rights in the App and the Services are licensed (not sold) to you. You have no intellectual property rights in, or to, the App, the Documentation or the Services other than the right to use them in accordance with these terms.
OUR RESPONSIBILITY FOR LOSS OR DAMAGE SUFFERED BY YOU
We are responsible to you for foreseeable loss and damage caused by us. If we fail to comply with these terms, we are responsible for loss or damage you suffer that is a foreseeable result of our breaking these terms or our failing to use reasonable care and skill, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if either it is obvious that it will happen or if, at the time you accepted these terms, both we and you knew it might happen.
We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors or for fraud or fraudulent misrepresentation.
We are not liable for business losses. The App is for domestic and private use. If you use the App for any commercial, business or resale purpose we will have no liability to you for any loss of profit, loss of business, business interruption, loss of business opportunity or for any other commercial or business losses.
Limitations to the App and the Services. The App and the Services are provided for general information and entertainment purposes only. They do not offer advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of information obtained from the App or the Service. Although we make reasonable efforts to update the information provided by the App and the Service, we make no representations, warranties or guarantees, whether express or implied, that such information is accurate, complete or up to date.
The App and Service is a free service offered to invited residents of the Site, and others that we personally invite. The App and Service are provided on an ‘as-is’ basis. We do not represent, guarantee or warrant that the App and Service will be uninterrupted or error free.
Please back-up content and data used with the App. We recommend that you back up any content and data used in connection with the App, to protect yourself in case of problems with the App or the Service.
Check that the App and the Services are suitable for you. The App and the Services have not been developed to meet your individual requirements. Please check that the facilities and functions of the App and the Services meet your requirements.
Please use up to date anti-virus software: We recommend that you use up to date anti-virus software on any device used to access the App and Service. We do not warrant, represent or guarantee that the App or Service will be free of viruses or other malware.
We are not responsible for events outside our control. If our provision of the Services or support for the App or the Services is delayed by an event outside our control, we will not be liable for delays caused by the event.
WE MAY END YOUR RIGHTS TO USE THE APP AND THE SERVICES
We may end your rights to use the App and Services at any time by contacting you if you have broken these terms. If what you have done can be put right, we may give you a reasonable opportunity to do so but we are not obliged to do so.
Your rights to use this App will also end if you are no longer a resident of the Site, or if you have been otherwise personally invited by us and we withdraw our invitation.
If we end your rights to use the App and Services:
You must stop all activities authorised by these terms, including your use of the App and any Services.
You must delete or remove the App from all devices in your possession and immediately destroy all copies of the App which you have and confirm to us that you have done this.
We may remotely access your devices and remove the App from them and cease providing you with access to the Services.
We will disable your password so that you cannot access the App and Service.
WE MAY TRANSFER THIS AGREEMENT TO SOMEONE ELSE
We may transfer our rights and obligations under these terms to another organisation. We will always tell you in writing if this happens and we will ensure that the transfer will not affect your rights under the contract.
YOU MAY NOT TRANSFER YOUR RIGHTS TO SOMEONE ELSE
You may not transfer your rights or your obligations under these terms to another person.
NO RIGHTS FOR THIRD PARTIES
This agreement does not give rise to any rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of this agreement.
IF A COURT FINDS PART OF THIS CONTRACT ILLEGAL, THE REST WILL CONTINUE IN FORCE
Each of the paragraphs of these terms operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect.
EVEN IF WE DELAY IN ENFORCING THIS CONTRACT, WE CAN STILL ENFORCE IT LATER
Even if we delay in enforcing this contract, we can still enforce it later. If we do not insist immediately that you do anything you are required to do under these terms, or if we delay in taking steps against you in respect of your breaking this contract, that will not mean that you do not have to do those things and it will not prevent us taking steps against you at a later date.
WHICH LAWS APPLY TO THIS CONTRACT AND WHERE YOU MAY BRING LEGAL PROCEEDINGS
These terms are governed by English law and you can bring legal proceedings in respect of the products in the English courts.
FAIR PROCESSING NOTICE – Chapter Service App
This Fair Processing Notice explains how Greystar Europe Holdings Limited (‘GEHL’) and Ping-Services Limited (‘we’ or ‘us’) will store and use personal data that is collected from you when you use the Chapter Service mobile application software (‘the App’), the data supplied with the software and App, and any updates or supplements to it.
GEHL is the ‘controller’ and Ping-Services Limited the ‘processor’ of personal data collected through the App for the purposes of applicable data protection laws.
You can manage your information through the settings, and are able to edit or delete any posts you make within the App by selecting the three dots that appear to the right of the post. Information on how to exercise your data subject rights is included at the end of this notice.
If you post a comment into the public areas of the App, this will be viewable by all residents who are signed up to the App, along with your name and profile photograph you choose to include via the App.
We will use the information you provide to us via the App:
Transfers of personal data
Recipients of personal data / service providers
We will disclose the personal data we hold about you to:
Ping-Services where you decide to use their concierge services. The data they process will not leave the UK. They will act as a processor for your personal data and their privacy policy is available here (below).
Ping-Services Limited who provide the App services to us, and their sub processors Digital Ocean and Amazon AWS.
Where we store your personal data;
The data we collect is stored on information technology systems owned and run by or on behalf of GEHL or on systems run by those businesses processing it on GEHL's behalf. All information you provide to us is stored on secure servers.
Our legal basis for processing your personal data
If you are a resident using the App, our legal basis for processing your personal data is that it is within our Legitimate Interest in order that we may arrange for the provision of services to you. We consider that our legitimate interests do not override your rights in so far as users of the App have discretion regarding which services they may wish to obtain.
In certain circumstances, it may be necessary to use data obtained via the App for the purpose of entering into, managing, or terminating an agreement with you in relation to services made available via the App.
If you otherwise contact us via the App or in relation to your data protection rights, our legal basis for processing your personal data is that it is necessary for our legitimate interest in conducting our business and meeting the requirements of customers.
Retention of personal data
We store the personal data we collect about you only for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory or other compliance obligations.
Your rights
Information on your rights, how to complain, and how to contact Ping Services Protection Officer, is available within our privacy policy (below).
PING SERVICES LTD PRIVACY POLICY
BACKGROUND:
Ping Services Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits (“Our Platform”), procures our services, as well as every resident and customer we serve. We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested upon entering Our Platform and continuing to use it. We will also make sure that you have agreed to be a resident of our customers’, and have agreed to this Privacy Policy, by providing you with an easy method to opt out of our emails if you disagree.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
2. Information About Us
Our Site and the associated App is owned and operated by Ping Services Ltd, a limited company registered in England under company number 12319160.
Registered address: Office 6, Town Hall, 86 Watling Street East, Towcester, Northants, NN12 6BS, England.
3. What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Platform, our Services, and when you become a resident that we connect to our customers. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that if data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i) Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6. What Data Do You Collect and How?
Depending upon your use of Our Platform, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policy.
Data Collected
How We Collect the Data
Third Parties whose content appear on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
8. How and Where Do You Store or Transfer My Personal Data?
We only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
9.1 In order to conduct our fundamental services to our customers, data pertaining to prospects will be shared to them, while taking steps to ensure that personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
9.2 If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
9.3 In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
9.4 We may share your personal data with other companies for the performances of the service we offer to you.
9.5 If any of your personal data is shared with a third party, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
9.6 If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.
10. How Can I Control My Personal Data?
10.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails, at the point of providing your details, or by managing your Account.
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site, and our Services you may be required to submit or allow for the collection of certain data.
You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy.
If you are a Prospect, you can opt out of our cold emails by indicating such intention when you receive them. If you want to know the data we collect from Prospects, you can check Clauses 6 and 7.
12. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests may be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make multiple repetitive requests for information we have previously provided) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
13. How Do You Use Cookies?
Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for marketing and optimisation purposes. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a message box requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
You may find further details and information about the specific first party, third party and analytics cookies that we use on our platform within our Cookie Policy.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, or to otherwise exercise your data protection rights, please use the following details:
Should you have any complaint regarding our use of your personal data, we would ask that you contact us in the first instance so that we can assist you. You also have the right to complain to the Information Commissioner’s Office. You can contact them in the following ways:
15. Changes to this Privacy Policy
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Platform and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 04/12/2023.