Privacy Policy

Introduction

The purpose of this Fair Processing Notice (“Notice”) is to inform you about how PARATUS Holding GmbH, along with its affiliates and subsidiaries (“we”, “us”, “our”), will process your personal data as a data controller. It also outlines the measures and processes we have put in place to ensure its adequate protection. This Notice complies with the General Data Protection Regulation 2016/679 (“GDPR”).

Please note that this Notice does not create any contractual relationship between you and us, and we may amend it from time to time.
Below is a brief overview of what happens to your personal data when you visit our website. Personal information refers to any data that can identify you as an individual. Detailed information on data protection can be found in our privacy policy, which is provided below.

Lawful Processing

We will only process your personal data:

  • When you have given your consent;
  • when the processing is necessary to provide our products or services to you/your employer;
  • when the processing is necessary to respond to a request from you/your employer;
  • when the processing is necessary to maintain our relationship with you/your employer;
  • when the processing is necessary for compliance with our legal and regulatory obligations
  • In case of above, you may withdraw your consent at any time.

What personal data we collect about you

We may collect the following types of personal data:

Contact Information:

  • Name
  • Email address
  • Phone number
  • Mailing address
  • Other contact details

Employment Information:

  • Job title
  • Department
  • Role or position within your organization or employer

Communication Preferences:

  • Preferences for marketing materials, newsletters, or events
  • Responses to surveys or questionnaires

Access Information:

  • Details of your access to our premises (e.g., visitor logs)
  • IP address, browser type, and operating system for website interactions
  • Login credentials (for secure areas of websites or systems)

Feedback and Interactions:

  • Messages or feedback provided via email, surveys, or direct communication
  • Contributions to online forums, events, or webinars

How we collect personal data

At PARATUS, we collect personal data to support the growth and success of our software group, which includes both organic development and the integration of new partners. As a community of independent partners sharing common values, leadership principles, and service guidelines, we maintain flexibility and entrepreneurial agility to ensure that all stakeholders—employees, shareholders, customers, and ultimately patients—benefit from our services and ongoing technological advancements.

We collect personal data in the following ways:

Direct Interactions:

We collect personal data directly from individuals when they engage with us, such as when employees, customers, or potential partners provide their contact information, sign agreements, or participate in surveys and feedback sessions.

Through Our Services:

When individuals use our software or services, we collect relevant data to ensure the provision of our services and to improve customer experiences. This includes data related to usage patterns, preferences, and feedback.

Third-Party Partners:

We may also collect personal data through third-party partners who are integral to our operations and who share our commitment to maintaining confidentiality and data protection. These partners may include service providers, technology vendors, or industry collaborators.

Publicly Available Sources:

In some cases, we may obtain personal data from publicly accessible sources to enhance our business operations and network, ensuring that we connect with relevant partners and customers in a compliant manner.

Our commitment is to handle this personal data responsibly and transparently, ensuring compliance with applicable data protection laws. We take all necessary measures to protect personal data, maintaining the privacy and security of the information shared with us.

Purpose of Data Collection

The personal data we collect is used to maintain relationships with customers, partners, and employees, improve our services, ensure compliance with legal and regulatory requirements, and foster sustainable growth within our group. We focus on long-term, partnership-based engagements that benefit all parties involved, preserving the entrepreneurial spirit, culture, and values at the heart of the PARATUS Group.

By collecting and managing personal data in a responsible manner, we aim to provide a stable, long-term environment that encourages entrepreneurial success and contributes to the growth of our modern, future-oriented business community.

What rights do you have

You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice if you have further questions about the issue of privacy and data protection. You may also, of course, file a complaint with the competent regulatory authorities.

General information and mandatory information

In accordance with applicable data protection laws, we provide the following general and mandatory information regarding the processing of personal data:

Identity and Contact Information of the Data Controller: The data controller responsible for the processing of your personal data is:

PARATUS Holding GmbH
Theatinerstr. 14
80333 München

Purpose of Data Collection:

We collect and process personal data for the following purposes:

To manage our business operations and relationships with customers, employees, and partners.

To improve and personalize our services.

To comply with legal and regulatory obligations.

To maintain communication and provide information on services, products, and offers.

To ensure data security and protect our systems.

Legal Basis for Data Processing:

The legal basis for processing your personal data may include:

Consent, where you have given us permission to process your data.

Contractual necessity, where data is required for the performance of a contract (e.g., with customers or partners).

Compliance with legal obligations (e.g., tax or regulatory requirements).

Legitimate interests pursued by us or third parties (e.g., improving our services).

Recipients of the Personal Data:

Your personal data may be shared with third-party service providers who assist us with our operations (e.g., IT services, marketing, legal or financial services). We ensure that all third parties adhere to strict data protection standards and are contractually obligated to handle your data securely.

Data Retention Period:

Personal data will be retained only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Once the retention period has expired, your data will be securely deleted or anonymized.

Rights of the Data Subject:

You have the right to:

Access your personal data and receive information about its processing.

Request correction or deletion of inaccurate or incomplete data.

Object to the processing of your data or request its restriction.

Withdraw consent, if the processing is based on consent.

Lodge a complaint with a data protection authority if you believe that your rights have been violated.

Transfer of Personal Data to Third Countries:

If we transfer your personal data outside the European Economic Area (EEA), we will ensure that adequate safeguards are in place to protect your data in accordance with applicable data protection laws.

Obligation to Provide Personal Data:

Providing personal data is generally voluntary. However, in certain cases (e.g., contractual relationships or legal obligations), failure to provide personal data may result in our inability to provide services or fulfill contractual obligations.

By ensuring that personal data is handled transparently and responsibly, we aim to build trust with all stakeholders and comply with data protection regulations.

Notice concerning the party responsible for this website

PARATUS Holding GmbH

Theatinerstr. 14
80333 München

Germany

Managing Directors: Friedrich Von Kleist, Jürgen Heilmann

Seat: Munich I District Court of Munich I HRB 258182

Tax ID 143 / 169 / 31732

VAT ID DE345951525

The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, email addresses, etc.).

Revocation of your consent to the processing of your data

Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.

Right to file complaints with regulatory authorities

If there has been a breach of data protection legislation, the person affected may file a complaint with the competent regulatory authorities. The competent regulatory authority for matters related to data protection legislation is the data protection officer of the state in which our company is headquartered. A list of data protection officers and their contact details can be found at the following link:
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

Right to data portability

You have the right to have data which we process based on your consent or in fulfillment of a contract automatically delivered to yourself or to a third party in a standard, machine-readable format. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.

Information, blocking, deletion

As permitted by law, you have the right to be provided at any time with information free of charge about any of your personal data that is stored as well as its origin, the recipient and the purpose for which it has been processed. You also have the right to have this data corrected, blocked or deleted. You can contact us at any time using the address given in our legal notice if you have further questions on the topic of personal data.

Data collection on our website

Cookies

Some of our web pages use cookies. Cookies do not harm your computer and do not contain any viruses. Cookies help make our website more user-friendly, efficient, and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called “session cookies.” They are automatically deleted after your visit. Other cookies remain in your device’s memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site.

You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of this website.

Cookies which are necessary to allow electronic communications or to provide certain functions you wish to use (such as the shopping cart) are stored pursuant to Art. 6 paragraph 1, letter f of GDPR. The website operator has a legitimate interest in the storage of cookies to ensure an optimized service provided free of technical errors. If other cookies (such as those used to analyze your surfing behavior) are also stored, they will be treated separately in this privacy policy.

Server log files

The website provider automatically collects and stores information that your browser automatically transmits to us in “server log files”. These are:

Browser type and browser version

  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address
  • These data will not be combined with data from other sources.

The basis for data processing is Art. 6 (1) (b) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.

Contact forms

Should you send us questions via our forms (contact, product request, sales partner application and reports), we will collect the data entered on the form, including the contact details you provide, to answer your question and any follow-up questions. We do not share this information without your permission.

We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1)(a) GDPR. You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.

We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.

Registration on this website

You can register on our website to access additional functions offered here. The mandatory information requested during registration must be provided in full. Otherwise, we will reject your registration.

To inform you about important changes such as those within the scope of our site or technical changes, we will use the email address specified during registration.

We will process the data provided during registration only based on your consent per Art. 6 (1)(a) GDPR. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.

We will continue to store the data collected during registration for as long as you remain registered on our website. Statutory retention periods remain unaffected.

Registration with Facebook Connect

Instead of registering directly on our website, you may also register using Facebook Connect. This service is provided by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

If you decide to register with Facebook Connect, you will be automatically redirected to the Facebook platform. There you can log in with your Facebook username and password. This will link your Facebook profile to our website or services. This link gives us access to your data stored on Facebook.

Including especially your:

  • Facebook name
  • Facebook profile picture
  • E-Mail address provided to Facebook
  • Facebook ID
  • Birthday
  • Gender
  • Country
  • This data will be used to set up, provide, and personalize your account.

For more information, see Facebook’s Terms of Use and Privacy Policy. These can be found at
www.facebook.com/about/privacy/ and www.facebook.com/legal/terms/

Registration with Google+

Instead of registering directly on our website, you may also register using Google+. This service is provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

If you decide to register with Google+, you will be automatically redirected to the Google+ platform. There you can log in with your Google+ username and password. This will link your Google+ profile to our website or services. This link gives us access to your data stored on Google+.

Including especially your:

  • Google+ name
  • Google+ profile picture
  • Google+ cover picture
  • Email address provided to Google+
  • Google+ ID
  • Birthday
  • Gender
  • Country

This data will be used to set up, provide, and personalize your account.

For more information, see Google’s Terms of Use and Privacy Policy.

These can be found at policies.google.com/terms, www.google.com/+/policy/pagesterms.html and policies.google.com/privacy

Registration with GitHub

Instead of registering directly on our website, you may also register using GitHub. This service is provided by GitHub, Inc, 88 Colin P Kelly Jr St, San Francisco, CA 94107, USA.

If you decide to register with GitHub, you will be automatically redirected to the GitHub platform. There you can log in with your GitHub username and password. This will link your GitHub profile to our website or services. This link gives us access to your data stored on GitHub.

Including especially your:

  • GitHub name
  • GitHub profile picture
  • GitHub cover picture
  • E-Mail address provided to GitHub
  • GitHub ID
  • Birthday
  • Gender
  • Country

This data will be used to set up, provide, and personalize your account.

For more information, see GitHub’s Terms of Use and Privacy Policy.

These can be found at help.github.com/articles/github-terms-of-service/ and help.github.com/articles/github-privacy-statement/.

Processing of data (customer and contract data)

We collect, process, and use personal data only insofar as it is necessary to establish, or modify legal relationships with us (master data). This is done based on Art. 6 (1) (b) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract. We collect, process and use your personal data when accessing our website (usage data) only to the extent required to enable you to access our service or to bill you for the same.

Collected customer data shall be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.

Data transferred when signing up for services and digital content

We transmit personally identifiable data to third parties only to the extent required to fulfill the terms of your contract with us, for example, to banks entrusted to process your payments.

Your data will not be transmitted for any other purpose unless you have given your express permission to do so. Your data will not be disclosed to third parties for advertising purposes without your express consent.

The basis for data processing is Art. 6 (1) (b) GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.

Analytics and advertising

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”).

reCAPTCHA is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.

The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that such an analysis is taking place.

Data processing is based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in protecting its site from abusive automated crawling and spam.

For more information about Google reCAPTCHA and Google’s privacy policy, please visit the following links: www.google.com/intl/de/policies/privacy/ and www.google.com/recaptcha/intro/android.html.

Newsletter

Newsletter data

We update you via email around once a month with news about our products, e.g. new product versions, updates, updates and bugs, the user forum and medical imaging in general. We require a valid email address as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive this newsletter. No additional data is collected or is only collected on a voluntary basis. We only use this data to send the requested information and do not pass it on to third parties.

We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) GDPR. You can revoke consent to the storage of your data and email address as well as their use for sending the newsletter at any time, e.g. through the “unsubscribe” link in the newsletter. The data processed before we receive your request may still be legally processed.

The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted. Data we have stored for other purposes (e.g. email addresses for the members area) remain unaffected.

Plugins and tools

YouTube

Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited.

If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.

YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.

Further information about handling user data, can be found in the data protection declaration of YouTube under www.google.de/intl/de/policies/privacy.

Google Web Fonts

For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

When you call up a page of our website that contains a social plugin, your browser makes a direct connection with Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.

If your browser does not support web fonts, a standard font is used by your computer.

Further information about handling user data, can be found at developers.google.com/fonts/faq and in Google’s privacy policy at www.google.com/policies/privacy/.

Vimeo

Our website uses features provided by the Vimeo video portal. This service is provided by Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA.

If you visit one of our pages featuring a Vimeo plugin, a connection to the Vimeo servers is established. Here the Vimeo server is informed about which of our pages you have visited. In addition, Vimeo will receive your IP address. This also applies if you are not logged in to Vimeo when you visit our website or do not have a Vimeo account. The information is transmitted to a Vimeo server in the US, where it is stored.

If you are logged in to your Vimeo account, Vimeo allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your Vimeo account.

For more information on how to handle user data, please refer to the Vimeo Privacy Policy at vimeo.com/privacy.

Google Maps

This site uses the Google Maps map service via an API. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.

The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.

Further information about handling user data, can be found in the data protection declaration of Google at www.google.de/intl/de/policies/privacy/.

SoundCloud

On our pages, plugins of the SoundCloud social network (SoundCloud Limited, Berners House, 47-48 Berners Street, London W1T 3NF, UK) may be integrated. The SoundCloud plugins can be recognized by the SoundCloud logo on our site.

When you visit our site, a direct connection between your browser and the SoundCloud server is established via the plugin. This enables SoundCloud to receive information that you have visited our site from your IP address. If you click on the “Like” or “Share” buttons while you are logged into your SoundCloud account, you can link the content of our pages to your SoundCloud profile. This means that SoundCloud can associate visits to our pages with your user account. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it will be used by SoundCloud. For more information on SoundCloud’s privacy policy, please go to soundcloud.com/pages/privacy.

If you do not want SoundCloud to associate your visit to our site with your SoundCloud account, please log out of your SoundCloud account.

Veoh

Our website uses features provided by the Veoh video portal. This service is provided by FC2, 4730 South Fort Apache Road, Suite 300, Las Vegas, NV 89147, USA.

If you visit one of our pages featuring a Veoh plugin, a connection to the Veoh servers is established. Here the Veoh server is informed about which of our pages you have visited. In addition, Veoh will receive your IP address. This also applies if you are not logged in to Veoh when you visit our website or do not have a Veoh account. The information is transmitted to a Veoh server in the US, where it is stored.

If you are logged in to your Veoh account, Veoh allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your Veoh account.

For more information on how to handle user data, please refer to the Veoh Privacy Policy at www.veoh.com/corporate/privacypolicy.

Dailymotion

Our website uses features provided by the Dailymotion video portal. This service is provided by Dailymotion, 140 boulevard Malesherbes, 75017 Paris, France.

If you visit one of our pages featuring a Dailymotion plugin, a connection to the Dailymotion servers is established. Here the Dailymotion server is informed about which of our pages you have visited. In addition, Dailymotion will receive your IP address. This
also applies if you are not logged in to Dailymotion when you visit our website or do not have a Dailymotion account.

If you are logged in to your Dailymotion account, Dailymotion allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your Dailymotion account.

For more information on how to handle user data, please refer to the Dailymotion Privacy Policy at www.dailymotion.com/legal/privacy.

GitHub

Our website uses features provided by the GitHub. This service is provided by GitHub, Inc, 88 Colin P Kelly Jr St, San Francisco, CA 94107, USA.

If you visit one of our pages featuring a GitHub plugin, a connection to the GitHub servers is established. Here the GitHub server is informed about which of our pages you have visited. In addition, GitHub will receive your IP address. This also applies if you are not logged in to GitHub when you visit our website or do not have a GitHub account. The information is transmitted to a GitHub server in the US, where it is stored.

If you are logged in to your GitHub account, GitHub allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your GitHub account.

For more information on how to handle user data, please refer to the GitHub Privacy Policy at help.github.com/articles/github-privacy-statement/.

Spotify

Our website uses features provided by the Spotify. This service is provided by Spotify AB, Birger Jarlsgatan 61, 113 56 Stockholm, Sweden.

If you visit one of our pages featuring a Spotify plugin, a connection to the Spotify servers is established. Here the Spotify server is informed about which of our pages you have visited. In addition, Spotify will receive your IP address. This also applies if you are not logged in to Spotify when you visit our website or do not have a Spotify account.

If you are logged in to your Spotify account, Spotify allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your Spotify account.

For more information on how to handle user data, please refer to the Spotify Privacy Policy at www.spotify.com/de/legal/privacy-policy/.

Instagram

Our website uses features provided by the Instagram. This service is provided by Instagram Inc., 1601 Willow Road, Menlo Park, CA 94025, USA.

If you visit one of our pages featuring an Instagram plugin, a connection to the Instagram servers is established. Here the Instagram server is informed about which of our pages you have visited. In addition, Instagram will receive your IP address. This also applies if you are not logged in to Instagram when you visit our website or do not have a Instagram account. The information is transmitted to an Instagram server in the US, where it is stored.

If you are logged in to your Instagram account, Instagram allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your Instagram account.

For more information on how to handle user data, please refer to the Instagram Privacy Policy at https://instagram.com/about/legal/privacy/.

XING

We have a profile on XING. The provider is New Work SE, Dammtorstr. 30, 20354 Hamburg, Germany. For details on how they handle your personal data, please refer to XING’s privacy policy: https://privacy.xing.com/en/privacy-policy.

Font Awesome (local hosting)

This site uses Font Awesome for consistent font rendering. Font Awesome is installed locally. There is no connection to Fonticons, Inc. servers.

For more information about Font Awesome, please see the Font Awesome privacy policy at: https://fontawesome.com/privacy.

International transfers of personal data

Your personal data may be transferred to (including accessed in or stored in) a country or territory outside the European Economic Area (“EEA”), including to countries whose laws may not offer the same level of protection of personal data as are enjoyed within the EEA. We may share your personal data with our group companies outside of the EEA including Japan. We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the GDPR. You can obtain copies of the relevant safeguard documents by making a request as set out in section 12 below.

When we may disclose your personal data

We do not and will not sell, rent out or trade your personal data. We will only disclose your personal data to the following recipients:

  • to our group companies;
  • to companies approved or designated by you.
  • to third parties who process your personal data on our behalf (such as our systems providers including cloud providers);
  • to third parties who process your personal data on their own behalf but through providing you or your employer with a service on our behalf (such as our suppliers);
  • to companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such information is shared.
  • to any third party to whom we assign or novate any of our rights or obligations.
  • to any prospective buyer in the event, we sell any part of our business or assets; and
  • to any government, regulatory agency, enforcement or exchange body or court where we are required to do so by applicable law or regulation or at their request.

How we protect your personal data

We are committed to safeguarding and protecting your personal data and will implement and maintain appropriate technical and organizational measures to ensure a level of security appropriate to protect your personal data from accidental or unauthorized destruction, loss, alteration, disclosure or access.

Your rights in relation to the personal data we collect

If you wish to:

  • update, modify, or delete your personal data, or obtain a copy of your personal data that we hold; or
  • restrict or stop us from using any of your personal data which we hold,

you can request this by contacting us.

In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification for us to comply with our security obligations and to prevent unauthorized disclosure of data.

How long we will hold your personal data for

We will only retain your personal data as long as necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

How we update or change this fair processing notice

We may change or update parts of this Notice to maintain our compliance with applicable law and regulation or following an update to our internal practices. We will do this by updating this Notice. You will not necessarily be directly notified of such a change. Therefore, please ensure that you regularly check this Notice, so you are fully aware of any changes or