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PRIVACY POLICY


PRIVACY POLICY

Updated July 6, 2023

Table of Contents

 1.  Introduction.
 2.  What Does this Privacy Policy Cover?
 3.  What Information Do We Collect or Receive?
     1. Directly from You.
     2. Third Party Service Providers and Partners.
     3. Cookies and Other Tracking Tools.
 4.  Why Do We Collect Personal Data?
 5.  What is the Legal Basis for the Processing of Personal Data?
 6.  How is Your Personal Data Used?
 7.  Who Do We Share Your Information With?
 8.  Data Retention.
 9.  How Do We Protect Your Information?
 10. Your EU and UK GDPR Privacy Rights and Controlling Your Personal Data.
 11. Children’s Privacy.
 12. Your California Privacy Rights.
 13. Your LGPD Privacy Rights.
 14. Changes to this Privacy Policy.
 15. How to Contact Us?

 


1. INTRODUCTION

Wellesley Information Services, its subsidiaries and affiliates (together,
“Wellesley,” “WIS”, “we”, “us” or “our”) is a leading global member community
for B2B enterprise technology.  Wellesley owns and operates SAPinsider,
Mastering SAP, Channel Metrics, and ERP Today which each manages global
websites and publishes or sponsors articles, blogs, newsletters, definitions,
surveys, research, and other original premium content spanning thousands of B2B
enterprise technology topics. As such, Wellesley appeals to a wide range of
individuals, some of whom casually visit our websites and reference our content
and others who register to become members of our network of websites. Our
website visitors and members are generally professionals in their respective
industries and, for those who chose to complete a registration form or otherwise
chose to become a member, gain access to these Preferred Membership Access
Services subject to the terms of this Privacy Policy and our Terms of Use. In
order for us to provide these Membership Access Services for free, members agree
to receive personalized content, ads, and sales and marketing communications
from us and our Partners (e.g., our clients that purchase our member contact
information through lead generation, content syndication, branding, digital
content experiences, magazine subscriptions, events, executive forums and other
similar products and services) that are relevant to their professional
interests. If you do not want to receive personalized content, ads, and sales
and marketing communications from Wellesley and its Partners, please do not
become a member. Importantly, you can unsubscribe from these communications at
any time, while continuing to receive free access to a significant level of our
content.

We are committed to your data protection and data privacy. We recommend you read
this Privacy Policy to better understand what information we collect, how we use
it, and who we may share it with. Additionally, this Privacy Policy will provide
you with details on how you can control the use and disclosure of your
information.

Please note that Wellesley is deemed a “data controller” as it relates to any
Personal Data or Personal Information (as those terms are defined by applicable
law) shared in connection with your use of our website, including your
membership information, as applicable. By visiting, joining, or using Wellesley,
or otherwise indicating that you agree to this Privacy Policy, you agree to, and
authorize our use of your Personal Information as described in this Privacy
Policy.

If you have any questions regarding this Privacy Policy, please contact us by
emailing us at: privacy@wispubs.com, or by writing to us at: Wellesley, Inc.,
Attn: Data Protection Officer, PO Box 982, Hampstead NH, USA 03841


2. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers information collected by Wellesley through its
websites and details the Personal Data that we process and collect from website
visitors, users completing a registration form to become a Wellesley member,
Service Providers and third parties who perform functions for us, personnel who
are our employees or authorized contractors, and job applicants. For purposes of
this Privacy Policy, Personal Data means any information relating to an
identified or identifiable natural person. From time to time, Wellesley may
utilize the services of third parties such as data append or data hygiene
service providers and receive other Personal Data from these service providers
to, among other things, ensure the accuracy of its membership records. As such,
Wellesley’s services may include Personal Data received from third parties.


3. WHAT INFORMATION DO WE COLLECT OR RECEIVE?

We collect or receive information in several different ways. In many cases you
choose what information to provide.

 1. Directly from You. We collect a variety of information from you when you
    provide it to us directly or when we request it from you. Some examples of
    these instances are as follows:
    * Personal Data that you Provide to Us. We receive, store, and collect any
      Personal Data you provide to us directly through one of our websites or
      give us in any other way, including business cards, emails, and telephone
      communications. For example, when you fill out and submit a registration
      form to become a Wellesley member, download a specific piece of content,
      request information on one of our products or services or hosted/attended
      and had your badge scanned as part of your attendance at such event, then
      we received your contact information including your company, name, work
      address, business email, phone number, job information, personal content
      preferences and geographic location. We may ask you for similar
      information at other times, such as subscribing to our newsletter or use
      our “Contact Us” forms.
    * Member Generated Content. Some of our websites feature member-generated
      content in the form of article submissions, event session materials, blog
      posts and comments. In order to submit content or participate in an event,
      an individual must first complete the applicable registration form. The
      information provided by the individual may be displayed in the
      individual’s public profile on our member expert pages on our websites and
      can be viewed by all visitors to the website.
 2. Third-Party Service Providers and Partners. We engage third-party service
    providers and partners to provide us with information, and we also use
    publicly available sources, to supplement our member account information to
    help improve personalization of our Preferred Member Access Services. For
    example:
    * Supplementary and Third-Party Information. We may collect, obtain, or
      supplement your Personal Data from third parties who license it to us or
      otherwise provide it to us. This may include information provided through
      telephone, mailings, or events, from customers, vendors, suppliers, third
      parties, or commercially available sources (e.g., data brokers, data
      aggregators, public databases, etc.), and from third-party partners or
      affiliates running co-branded campaigns or membership initiatives. For
      example, we may contract with a third-party partner or affiliate to
      contact you by email or telephone to determine if you would be interested
      in certain content tailored to your professional interest and/or becoming
      a member.
    * Public and Social Network Sources. We may collect or obtain your Personal
      Data from publicly accessible sources like corporate websites, business
      listings, or social networking platforms. You can opt-out of the third
      parties’ (such as a social media network or advertiser platform)
      collection and use of information for ad targeting by updating your
      account ad settings with the third party or by following the instructions
      regarding Tracking Technologies described in the paragraph below.
 3. Cookies and Other Tracking Tools. We use Cookies, Clear GIFs, Web Beacons,
    Tracking Technologies or other similar solutions (“Tracking Technologies”)
    to collect or receive certain information when you visit or use a Wellesley
    website or read an email, newsletter, or otherwise interact with content
    from us. These Tracking Technologies may include first-party cookies (i.e.,
    those placed by the website being visited) and third-party cookies (i.e.,
    those placed by a website other than the one being visited), local shared
    objects (commonly referred to as “Flash Cookies” or “HTML 5 Cookies”) and
    tracking pixels (including transparent or clear gifs).
    Cookies are small data files which are placed on your computer or mobile
    device when you visit a website or use an online service. For example,
    cookies enable us to identify and authenticate you and remember your
    preferences so we can enhance your experience on our websites. They also
    help us serve you ads relevant to your professional interests and to provide
    aggregated auditing, research, and reporting for advertisers, understand and
    improve our service, and know when content has been shown to you. Because
    your web browser may request advertisements and beacons directly from
    third-party ad network servers, these networks can view, edit, or set
    third-party cookies, just as if you had requested a web page from their
    site. Ads served by Wellesley may also set third-party cookies. Most
    browsers are initially set up to accept cookies, but you can reset your
    browser to refuse all cookies or to indicate when a cookie is being sent.

We strongly recommend that you leave the cookies activated, however, because
cookies enable you to take advantage of some of Wellesley’s website features,
and if you decline or delete them then parts of our website and Member Access
Services may not work properly. Even if you decline or delete cookies, you will
continue to be served with advertisements; however, they will not be tailored to
your preferences, usage patterns, or professional interests. Where legally
permitted, we will assume that you have agreed to receive all cookies on our
websites through your continued use; otherwise, your acceptance of such cookies
by way of your browser settings or our consent management tool shall be deemed
your acceptance of the use of such Tracking Technologies.

Wellesley and its Partners use several different types of cookies on our
websites, including the following.

 * Strictly Necessary Cookies. Strictly necessary cookies facilitate the
   operation of our websites. Without the use of these cookies, portions of our
   websites would not function properly. For example, we use essential cookies
   to help us identify which of our visitors have previously registered in order
   to access our Member Access Services.
 * Performance Cookies. Performance cookies help us monitor the performance of
   our websites and how users interact with them. These cookies collect
   information such as how often users visit our websites, what pages they visit
   when they do so, and what other websites they used prior to coming to our
   websites and provide us with information that allows us to improve our
   websites and services.
 * Functional Cookies. Functional cookies are used to remember your preferences
   on our websites and to authenticate your identity. For example, we use
   functional cookies to recognize and save your name and password on our
   websites.
 * Behavioral Advertising Cookies. Wellesley and its Partners use behavioral
   advertising cookies in order to provide you with advertising which is
   tailored to your interests when you visit websites on and off our network.
   Behavioral advertising cookies analyze information about your interests and
   your browsing history and provide you with advertisements on and off our
   network that match these interests. Behavioral advertising is a type of
   advertising that is based upon your web browsing activity over a period of
   time – so it’s different than advertising you may see when you’re looking for
   something online using a search engine (e.g., Google, Yahoo, or Bing) or on a
   website you may be visiting at a particular time. As an example, you may be
   doing research on products and services related to data center
   virtualization. If a data center virtualization provider is conducting an
   advertising campaign on our network, as you browse the relevant portions of
   our websites, then we may serve you with an advertisement of one of their
   solutions.

Although our websites currently do not respond to “do not track” browser
headers, you can limit tracking through third-party programs and by taking the
other steps discussed in this section. You may opt-out of Wellesley’s
internet-based advertising by removing cookies or by setting your web browser
settings to refuse cookies and similar Tracking Technologies. Please note that
web browsers operate using different identifiers. As such, you must adjust your
settings in each web browser and for each computer or device that you would like
to opt-out on. Further, if you simply delete your cookies, you will need to
remove cookies from your device after every visit to websites. You may download
a browser plugin that will help you maintain your opt-out choices by
visiting www.aboutads.info/pmc. You may block cookies entirely by disabling
cookie use in your browser or by setting your browser to ask for your permission
before setting a cookie. Blocking cookies entirely may cause some websites to
work incorrectly.
Please note that the use of online tracking mechanisms by third parties, such as
our Partners, is subject to those third parties’ own privacy policies, and not
this Privacy Policy. You may remove yourself from the targeted advertising of
companies within the Network Advertising Initiative by opting out here, or of
companies participating in the Digital Advertising Alliance program by opting
out here, the Digital Advertising Alliance of Canada (DAAC) (for Canadian users)
by opting out here; or the European Interactive Digital Advertising Alliance
(EDAA) (for users in the EU) by opting out here.


4. WHY DO WE COLLECT PERSONAL DATA?

We collect Personal Data about you to provide you with the best and most useful
content and services and to offer you opportunities to obtain other products and
services from us and our Partners. By providing us with your Personal Data, we
can cater our content and services to your interests and ensure that you receive
relevant offers. Additionally, the collection and use of your Personal Data
helps us tailor and improve our services and communicate with you effectively as
we know many of our website visitors and members make use of a range of media
channels. Finally, collecting and sharing your Personal Data with our Partners
makes it possible to operate our business and provide you with free content,
products, or services relevant to your professional interests.


5. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA?

We only collect and process your Personal Data as permitted by applicable law.
These lawful bases include where it is: necessary for the performance of a
contract to which you are a party; necessary for us to take steps, at your
request, to enter into such a contract; necessary for the purposes of our
legitimate interests or those of a third party and not overridden by the
interests or fundamental rights and freedoms of any data subject; where you
provide us with consent; or necessary for compliance with a legal obligation to
which we are subject. Under applicable law, we may be obliged to secure and
maintain technical and organizational measures to protect the security of your
data, investigate and report any (suspected) breaches of those technical and
organizational measures, or comply with legal and regulatory obligations,
including, but not limited to, complying with minimum retention periods for
certain types of data.


6. HOW IS YOUR PERSONAL DATA USED?

We use, aggregate, and retain your Personal Data as needed to provide you with
access to content, products, events, and services catered to your professional
interests and for other legitimate business reasons. Some information is
required in order to use our websites, attend our events and for us to provide
the Preferred Member Access Services. At a high level, we use the Personal Data
that has been provided by you directly or indirectly:

 * To provide you with our Member Access Services including, publications, and
   information that you request, access, or which may be of interest to you
   (e.g., downloading whitepapers and newsletters, attending webinars, research
   report surveys, executive forum participation, event attendance regarding
   information you are researching);
 * To create your member profile and purchase-intent history;
 * To send you satisfaction questionnaires, surveys, and marketing information;
 * To deliver or display content, advertisements, and other materials that match
   your professional interests and responsibilities for the purposes of online
   behavioral advertising (e.g., displaying advertisements that relate to your
   business or research);
 * To tailor the newsletters delivered to you based on your activity, interests,
   and responsibilities;
 * For Wellesley and its Partners to contact you for direct marketing purposes
   regarding information about, and invitations for, products, services, and
   events relevant to your professional interests and responsibilities;
 * To communicate with you, advertise to you or invite you to join us on social
   media platforms on which you participate;
 * To offer you opportunities to connect directly with your peers and with
   providers of technologies, goods, and services that may be of interest to
   you;
 * To operate our websites and improve our products and services;
 * To understand trends, usage statistics, and purchase-intent data;
 * To respond to your product or service inquiries or support requests and
   comments;
 * To test and evaluate potential new products and features;
 * To diagnose and resolve problems, analyze trends, and monitor usage and
   resource needs; and
 * For any other purpose that we tell you about when you give us your Personal
   Data.

By way of example, we analyze information collected from you to (a) help us
recognize your computer as a previous visitor, and save and remember any
preferences that you may have while you were visiting one of our websites or a
co-branded website, (b) track, accumulate and report information on our website
and content usage to our Partners so that they can measure the effectiveness of
advertisements and content viewed on the website, (c) help us customize the
content that you are shown while visiting the websites and potentially other
websites, (d) to help us improve the quality and presentation of our content and
websites, (e) to personalize your user experience, and (f) identify market
sensitivities and relative market interest in specific product categories.
Wellesley also uses the information that is collected to link your activity to
your member account. Linking this activity allows our system to confirm your
identity on our websites and allows easy access to our content by saving and
recognizing member log-in information.

In addition to providing you with our own editorial content, we offer you the
opportunity to access the branded content and expertise of our Partners. When
you choose to take advantage of our Partner’s content or expertise, you choose
to have your Personal Data shared with them as well. Wellesley and its Partners
may use information collected from you directly to provide you with access to
content related to your interests based on your activity on our websites and
other information that you have shared with us. Wellesley and its Partners may,
subject to applicable law, also send you emails on topics of interest, marketing
research surveys, incentives, as well as promotional emails and direct marketing
offers for products and services. We also use your information in aggregated
form as well to understand our member base, and to market our services to our
customers. In addition, we may inform our customers that a pre-existing contact
in their marketing and sales databases is also a member of our websites subject
to the terms and conditions of their purchase of such services.


7. WHO DO WE SHARE YOUR INFORMATION WITH?

Wellesley shares information with service providers, affiliates, Partners, and
other third parties where it is necessary to meet the requirements of our Terms
of Use, to provide the Preferred Member Access Services, or for any other
purposes described in this Privacy Policy.

 * Partners. Wellesley provides Partners with access to business contact lists
   and reports that may include your Personal Data and information about your
   areas of interest derived from your opt-in activity on our websites and
   interaction with our content or Partner content that has been published on
   our websites. Partners use this information to contact you about products or
   services that are relevant to your professional interests. Wellesley’s
   contractual arrangements with its Partners, when subject to our
   standard terms and conditions, require, among other things, that our Partners
   (a) only use this information to contact you via email, telephone, mail or
   other means of communication for internal sales and marketing purposes; and
   (b) secure and protect your information in accordance with applicable law and
   our instructions. If you do not want this information shared, please see
   “Your Privacy Rights and Controlling Your Personal Data” below.
 * Vendors and Service Providers. Wellesley may provide your Personal Data to
   certain vendors and service providers who are working for or with Wellesley
   as described in this Privacy Policy and who require access to such
   information to facilitate the provision of our services, such as the
   provision of data storage or processing activities, member acquisition or
   lead generation services, or corporate auditing services. Wellesley will
   always attempt to limit the information that we provide to what is reasonably
   sufficient for those vendors or service providers to carry out their
   responsibilities as they relate to the fulfillment of our services.
 * Third-Party Analytics and Interest-Based Advertising Partners. We allow our
   third-party analytics and interest-based advertising partners to collect
   certain information on our websites, as described above in Section 3.
 * Business transfers, Affiliates, and Subsidiaries. We may share or transfer
   the information that we collect in connection with, or during negotiations
   of, any merger, sale of company assets, financing, or acquisition of all or a
   portion of our business to another company. We may share your Personal Data
   within our organization, including with our affiliates and subsidiaries, in
   order to facilitate the provision of services in connection with your use of
   our websites or your membership to our network of websites.
 * Vital Interests. We may disclose the information that we collect where we
   believe that it is necessary in order to protect the vital interests of any
   person, or to exercise, establish, or defend our legal rights.
 * Other ways in which you specifically consent. We may share the information
   that we collect in other ways that you specifically consent.
 * Legal Compliance and Public Safety. We may share your Personal Data when
   required by law, subpoena, or other legal process or if we have a good faith
   belief that disclosure is reasonably necessary to (a) investigate, prevent,
   or take action regarding suspected or actual illegal activities or to assist
   government enforcement agencies; (b) enforce our agreements, (c) investigate
   and defend ourselves against any third-party claims or allegations, (d)
   protect the security or integrity of our services; or (e) exercise or protect
   the rights and safety of our members, personnel, or others. We may attempt to
   notify members about legal demands for their Personal Data when appropriate
   in our judgment, unless prohibited by law or court order or when the request
   is an emergency. We may dispute such demands when we believe, in our
   discretion, that the requests are overbroad, vague or lack proper authority,
   but we do not promise to challenge every demand.


8. DATA RETENTION.

We retain your information as necessary to comply with our legal obligations,
resolve disputes, and enforce our agreements. We will retain member’s Personal
Data for so long as a member’s account remains in existence or as needed to
provide our Member Access Services to our member, to comply with our legal
obligations, to resolve disputes, and to enforce our agreements. We may retain
Personal Data after a member has cancelled their membership if retention is
reasonably necessary to comply with our legal obligations, meet regulatory
requirements, resolve disputes, prevent fraud and abuse, or enforce this Privacy
Policy and our Terms of Use. We may also retain Personal Data, for a limited
period, if requested by law enforcement.


9. HOW DO WE PROTECT YOUR INFORMATION?

Wellesley takes the security of the data that it collects very seriously.
Wellesley has implemented a myriad of technical, organizational and
administrative measures which are generally accepted by the industry to protect
the Personal Data in its possession. These measures include, but are not limited
to, the implementation of current security technologies and processes to protect
your information from loss, misuse and unauthorized access, disclosure,
alteration or destruction. Our security systems include authenticated access to
internal databases, regular audits of processes and procedures, scheduled
reviews of overall web security, and the use of restrictions of access to
Personal Data in our possession. Additionally, we use encryption (HTTPS/TLS) to
protect data transmitted to and from our websites.


10. YOUR EU AND UK GDPR PRIVACY RIGHTS AND CONTROLLING YOUR PERSONAL DATA.

If you wish to access, rectify, erase, restrict, transfer, or object to the use
of your information, or deactivate your membership,  please send us an email
at privacy@wispubs.com.

Every email sent by or on behalf of Wellesley includes information as to how you
can easily unsubscribe from future communications.

Subject to applicable law, you have the following rights in relation to your
Personal Data:

 * Right of access: If you ask us, we will confirm whether we are processing
   your Personal Data and, if so, provide you with a copy of that Personal Data
   (along with certain other details). If you require additional copies, we may
   need to charge a reasonable fee.
 * Right to rectification: If your Personal Data is inaccurate or incomplete,
   you are entitled to have it rectified or completed. If we have shared your
   Personal Data with others, we will tell them about the rectification where
   possible. If you ask us, where possible and lawful to do so, we will also
   tell you with whom we shared your Personal Data so that you can contact them
   directly. We may need to charge a reasonable fee to research and compile the
   information into a report.
 * Right to erasure: You may ask us to delete or remove your Personal Data and
   we will do so in some circumstances, such as where we no longer need it (we
   may not delete your data when other interests outweigh your right to
   deletion, for example if we are required by law to keep it). If we have
   shared your data with others, we will tell them about the erasure where
   possible. If you ask us, where possible and lawful to do so, we will also
   tell you with whom we shared your Personal Data so that you can contact them
   directly. We may need to charge a reasonable fee to research and compile the
   information into a report.
 * Right to restrict processing: You may ask us to restrict or block the
   processing of your Personal Data in certain circumstances, such as where you
   contest the accuracy of that Personal Data or object to us processing it. We
   will tell you before we lift any restriction on processing. If we have shared
   your Personal Data with others, we will tell them about the restriction where
   possible. If you ask us, where possible and lawful to do so, we will also
   tell you with whom we shared your Personal Data so that you can contact them
   directly. We may need to charge a reasonable fee to research and compile the
   information into a report.
 * Right to data portability: You have the right to obtain your Personal Data
   from us that you consented to give us or that is necessary to perform a
   contract with you. We will give you your Personal Data in a structured,
   commonly used and machine-readable format. You may reuse it elsewhere.
 * Right to object: You may ask us at any time to stop processing your Personal
   Data, and we will do so if we are processing your Personal Data for direct
   marketing and otherwise. However, if we are relying on a legitimate interest
   to process your Personal Data and we demonstrate compelling legitimate
   grounds for the processing we may continue; or
 * Rights in relation to automated decision-making and profiling: You have the
   right to be free from decisions based solely on automated processing of your
   Personal Data, including profiling, which produces a significant legal effect
   on you, unless such profiling is necessary for entering into, or the
   performance of, a contract between you and us, or with your explicit consent.
 * Right to withdraw consent: If we rely on your consent to process your
   Personal Data, you have the right to withdraw that consent at any time. Your
   withdrawal of consent will not affect or apply to data that was processed
   prior to our receipt of your withdrawal of consent.
 * Right to lodge a complaint with the data protection authority: If you have a
   concern about our privacy practices, including the way we have handled your
   Personal Data, you can report it to the data protection authority that is
   authorized to hear those concerns.

In order to ensure the security of an individual’s Personal Information, we ask
that all requests from Authorized Agents be submitted via this method. Evidence
of a signed authorization to act on the behalf of the individual that is the
subject of the request, should be submitted as a PDF as part of this process.
Authorized Agents must also attest to their legal authority to submit
information on the behalf of each individual they represent. Please note, if an
authorized agent is unable to provide proof of authorization, their request may
be rejected.

Providing missing or inaccurate Personal Information on behalf of the individual
you are representing may also result in the request being denied, unless that
information is promptly corrected by the Authorized Agent.


11. CHILDREN’S PRIVACY.

Our products, services, events and offerings are directed to professionals. Our
business is not directed at children, and we do not solicit or knowingly collect
any personal information from children under the age of 16 without verifiable
parental consent. If you are not 18 or older, you are not authorized to use our
websites or services. Parents should be aware that there are parental control
tools available online that you can use to prevent children from submitting
information online without parental permission or from accessing material that
is harmful to minors. If you learn that a child under 13 has provided us with
Personal Data without consent, please contact us via the information provided
herein.


12. YOUR CALIFORNIA PRIVACY RIGHTS.

If you are a California resident, California Civil Code Section 1798.83 permits
you to request information regarding the disclosure of your personal information
to third parties for their direct marketing purposes. To learn more about your
California privacy rights, please read our CCPA Privacy Notice. To request a
list of the names and addresses of third parties to whom we disclosed such
information during the preceding calendar year along with a list of the
categories of information disclosed, please send an email
to privacy@wispubs.com.


13. YOUR LGPD PRIVACY RIGHTS.

If you are a resident of Brazil, the Lei Geral de Proteção de Dados Pessoais
(LGPD), Federal Law No. 13,709/2018, may provide you with additional privacy
rights with respect to the collection and use of your personal information. To
learn more about your Brazil privacy rights, please read our LGPD Privacy
Notice.


14. CHANGES TO THIS PRIVACY POLICY.

Wellesley may modify or amend this Privacy Policy from time to time. If we
change our Privacy Policy, we will post those changes in addition to updating
the “Last Updated” date at the top of this policy. We encourage you to read this
Privacy Policy regularly. Where applicable, your continued use of our Member
Access Services, our websites, or accessing content posted on our websites shall
constitute your acceptance of the modified or amended Privacy Policy. If there
will be any changes made to the use of your Personal Data in a manner materially
different from that stated at the time of collection, we will notify you by
posting a notice on our website.


15. HOW TO CONTACT US?

If you wish to exercise any rights that you may have to your Personal Data, you
can contact us via one of the below methods:

 



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