Privacy Policy

Introduction

This Privacy Policy describes how the “StartupSoft LLC” (hereinafter – the “Team”, “We”, “Our” and “Us”) may use your personal data (sometimes referred to as «personal information», «personally identifiable information» or «PII»), and provides information about your rights in relation to personal data (hereinafter – the “Privacy Policy”) in a situation when you visit our website (available at https://www.startupsoft.com/), or when you contact Us, or visiting Our social media profiles: LinkedIn, X, Instagram, Medium and Facebook. Hereinafter, visitors of our website and social media profiles are collectively referred to as “User(s)”. 

StartupSoft LLC, the owner and operator of the website: https://www.startupsoft.com/ (hereinafter – the “Website”). We are the “Controller” of the User(s) personal data (1) when We provide the following services to the User(s): Software Development, Product Development Outstaff, QA, UI/UX, and other custom service packages (collectively, the “Services”), (2) when We respond to a request from the User(s) who have contacted Us regarding Our Services using Our contact details set out in this Policy or on the Website, (3) when We contact potential staff members and/or individuals/legal entities who are interested in cooperating with Us, and (4) when the User(s) interacts with our Website.

We are required under data protection legislation to notify Our User(s) of the information contained in this Privacy Policy. This Privacy Policy does not in any way imply the conclusion of a principal cooperative agreement or any other relationship between Us and the User(s).

Please read Our Privacy Policy carefully to get a clear understanding of how we collect, use, protect, or otherwise handle your personally identifiable information in accordance with our Website.

Notice: Our Website may contain links to other websites that are not operated by Us. If a User(s) clicks on a third-party link on Our Website, such User(s) will be directed to that third party’s website. We strongly recommend that the User(s) review the privacy policy of each website that the User(s) visit. We have no control over and assume no responsibility for, the content, privacy policies, or practices of any third-party websites and/or services located outside Our Website.

DEFINITIONS

The terms used, such as “controller”, “processor”, “third party”, “personal data breach”, “personal data” or their “processing”, refer to the definitions in Article 4 of the GDPR.

The term “User” covers all categories of persons affected by data processing. These include our business partners, customers, potential customers, suppliers and other visitors to Our Website. The terms used, such as “Users” are to be understood gender-neutral.

“User(s)” under the CCPA is “Consumer(s)”, which means an individual residing in California. According to the law, a resident is defined as (1) any person present in the USA for reasons other than temporary or short-term purposes, and (2) any person who is a permanent resident of the USA but is currently outside the country for temporary or short-term reasons.

“Cookie files” – are small text files that are stored on the User’s device with which the User browses websites. They are commonly used to ensure the operation of websites and other services provided over the Internet, and to improve and develop these websites, which is done by reading the contents of these files.

“Data Controller” – for the purposes of the GDPR (General Data Protection Regulation), the term “Data Controller” denotes the Company as the legal entity that, either independently or in conjunction with others, decides on the purposes and methods for processing Personal Data.

“Personal Data” refers to any information that pertains to a person who can be identified, either directly or indirectly.

• Under the GDPR, Personal Data encompasses any details about you, such as your name, identification number, location data, online identifiers, or factors related to your physical, physiological, genetic, mental, economic, cultural, or social identity.
• According to the CCPA, Personal Data includes any information that identifies, relates to, describes, or can be reasonably linked to you, either directly or indirectly.

“Service Provider” is any individual or organization that processes data on behalf of the Company. This term includes third-party entities or individuals engaged by the Company to support, provide, or enhance the Service, or to help analyze the usage of the Service. Under the GDPR, Service Providers are classified as Data Processors.

“Usage Data” denotes information collected automatically, either through the use of the Service or from its infrastructure (such as the duration of a page visit).

“You” refers to the individual or entity accessing or using the Service, whether that be the individual directly or the company or other legal entity on whose behalf the individual is accessing or using the Service. Under the GDPR, “You” may also be referred to as the Data Subject or User, as You are the person utilizing the Service.

Notice: The above list of terms is not fixed, and therefore other terms are explained further in our Privacy Policy.

HOW AND WHAT PERSONAL INFORMATION WE COLLECT ABOUT THE USER(S)

The User(s) directly provide Us with most of the personal data we collect. We collect and process the following personal data:

• Personal data: We do not collect personal data such as name, date of birth, personal email address, telephone number, company name and Curriculum Vitae (in the case of employment) etc., when the User(s) visits our Website, unless the User(s) intentionally provide them through the contact forms for communication with us (for more details, see the “Contact Us”, “Career” sections) and/or when the User has provided personal consent through a pop-up questionnaire (by clicking the “Accept” button) on Our Website, or by signing any cooperation documents with Us, and hereby give full consent to the collection and processing of the User’s personal data. We will use this personal data to, but not limited to, respond to such User’s request and subsequently send the User several promotional or informational emails regarding Our Services. If the User(s) do not wish to receive such emails, an unsubscribe option will be provided in the email or, if the User(s) wishes, may send an email with a request to [email protected]. Sometimes, we also collect and process personal data that is public knowledge about a certain User(s) during a personal research process of the User(s) on LinkedIn or another social network.
• Non-personally identifiable data (such as the type of browser, referring website, date, and time of each User request, and other log data). Our purpose in collecting such information is to better understand how our Website is used and to maintain its proper functionality and usefulness for each User(s).
• Other information about the User, which combines parts of each of the previous ones: We collect other information that the User may provide to us when completing a survey from Us or participating in promotional/marketing offers, etc.

GROUNDS FOR COLLECTION OF PERSONAL DATA

Any process of User(s) personal data is performed only in accordance with this Privacy Policy, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (OJEU No L 119 of 4 May 2016) (the “General Data Protection Regulation” and “GDPR”), the UK Data Protection Act of 2018, The California Consumer Privacy Act of 2018 (the “CCPA”), and other regulatory acts.

We process personal data of User(s) only in compliance with the relevant data protection regulations. This means that Users’ data will only be processed if we have a legal permit. That is, especially if the data processing for the provision of Our Services is required or required by law, the consent of the user exists, as well as Our legitimate interests (i.e. interest in the analysis, optimisation and economic Operation and security of Our Services offer within the meaning of Art. 6 (1) lit. GDPR).

Note: We collect and process User’s personal data based on the following legal grounds, including but not limited to the following:

• Consent (Article 6(1)(a) GDPR): We process User’s data for marketing purposes based on User’s consent, which may be provided personal consent through a pop-up questionnaire (by clicking the “Accept” button) or by submitting forms on Our Website.
• Performance of a contract (Article 6(1)(b) GDPR): If User provides data for the purpose of purchasing Our Services or requesting a consultation, We process this data to fulfill the corresponding contractual obligations.
• Compliance with legal obligations (Article 6(1)(c) GDPR): In certain cases, We are required to process User’s data to comply with applicable legal requirements.
• Legitimate interest (Article 6(1)(f) GDPR): We may process User’s personal data when it is necessary for Our legitimate interests, such as improving Website performance, analyzing User interactions, or for recruitment purposes if User submits a CV. We ensure such processing respects User’s privacy rights.

PROTECTION AND USE OF PERSONAL DATA OF THE USER(S)

We use appropriate methods of personal data collection, storage and processing, as well as security measures to protect against unauthorised access, alteration, disclosure, or destruction of personal data of the User(s) and data stored on Our Website. We do not share personal data of the User(s) with third parties, except for Our affiliates, Our employees and/or subcontractors and recruitment service providers for Us, which have agreed in written consent not to collect, store, process and transfer the personal data of Our User(s) to other third parties without Our prior written permission. We always enter into agreements with each User(s) with whom we cooperate in various business areas that define the protection of our confidential information, which includes the personal data of the User(s).

We use User(s) personal data to (1) respond effectively to User(s) inquiries, (2) improve the quality of service to User(s), (3) facilitate the use of our Site, (4) fulfill Our risk management and fraud prevention obligations to protect User(s) and Us from misuse of Our Services, (5) inform User(s) about changes and new features of Our Services; (6) share with our marketing and advertising partners to further improve Our marketing strategies, (7) comply with local, national and international laws and regulations to be able to provide Our Services to the User(s). We may also use User(s)’ personal data to send newsletters, marketing or promotional materials and other information about our Services and our business.

We may be required to disclose all or any part of the User(s) personal data if required to do so by law or at the request of a governmental or regulatory organization/authority, or if We believe in good faith that such disclosure is necessary to (1) comply with legal or regulatory requirements or to conform to legal process; (2) to prevent crime; (3) to prevent any terrorist activity or threat to national security; (4) to protect and defend the property rights of “StartupSoft LLC”; (5) to protect the safety or welfare of the User(s), Our employees and/or subcontractors, or any other persons.

COOKIE FILES

When the User uses Our Website, browses Our Services, and uses the available systems (in particular, to create contact requests sent via the contact form), so-called “cookies” are created when the User browses these web pages.

We collect information contained in “cookies”, such as the date of the User’s connection to the Website or the IP-address of the device from which the User connects to the Website, which is data that shows how the User(s) use Our Websites. This information is used for administrative and statistical purposes and aimed at improving Our Website and enhancing User’s user experience. In addition, this automatically processed data may be used to analyse the behaviour of the content User(s) on Our Website (e.g., time spent on the Website) or to personalise the content of the Website’s web pages, in particular by providing online advertising.

The User(s) are not obliged to accept cookies (the User(s) may agree to the use of cookies by clicking the appropriate button on our Website or by making the appropriate settings in Your Web browser), but this may result in Our Website not functioning fully properly.

We use “Persistent Cookies” that are designed to store data over a long period of time and are activated each time the User visits Our Website that created that particular cookie. Each persistent Cookie is created with an expiry date that can be anywhere from a few days to several years in the future. When the Cookie expires, it is automatically deleted. Moreover, Persistent Cookies allow Our Website to “remember the User”.

First and Third Party Cookies on Our Website:

• Cookies placed on Your device include “First Party Cookies”, which are Cookies that are placed by Us or by third party service providers acting on Our behalf. If such Cookies are managed by third parties, We only allow the third parties to use the Cookies for Our purposes as described in this Cookie Policy and not for their own purposes.
• The Cookies placed on Your device may also include “Third Party Cookies”, which are Cookies placed there by third parties. These Cookies may include third-party advertisers who display advertisements on Our Website and/or social media providers, etc. They may also include third parties who provide video content embedded on Our Website (e.g. YouTube, etc). We have no control over the settings of these third-party cookies, so we encourage You to check the third-party websites to learn more about their use of cookies and how to manage them.

We also use social media buttons and/or plugins on the Website that allow You to connect with Our social network. In order for them to work (for example: social networks such as LinkedIn etc.), they set Cookies on Our Website that can be used to improve Your profile on their website or to supplement the data they store for various purposes specified in their respective privacy policies and cookies policies.

STORAGE OF OUR USER(S) PERSONAL DATA

We securely store Your data in Our internal Customer Relationship Management system (hereinafter – the “CRM”), that includes Gmail (from Google Mail).

The data retention period that we receive from the User(s) is calculated for each moment of cooperation individually in compliance with all relevant regulations, which are confirmed by this Privacy Policy (3 months and up). Retention periods from other recipients are set by them in their privacy policies.

In case the User(s) requests that We do not store personal data by sending Us a request to [email protected], We will take all reasonable measures to delete all personal data about such User(s). However, We will also offer to archive such User’s profile to create a fictitious profile of such User(s) with a single data field (e.g., e-mail only) to help link any future applications and to provide such User(s) with the opportunity to receive information about our recruitment campaigns.

YOUR RIGHTS (INCLUDING CHAPTER III, ARTICLES 15 – 21 OF THE GDPR)

The User(s) has(have) the following rights in connection with the processing of personal data by Us (the exercise of each of the following rights is carried out at the request of the User(s)):

• Submit a request to Us for access to the personal data of the User(s) (generally known as a “data subject access request”). This will allow the User(s) to obtain a copy of the personal data We hold about such User(s) and to verify that We are processing it lawfully.
• Request correction of the personal data We store about the User(s). This will allow the User(s) to correct any incomplete or inaccurate information that We store about the User(s).
• Request for deletion of personal information of the User(s). This allows the User(s) to ask Us to delete personal information if there are no compelling reasons for its further processing. The User(s) also have the right to ask Us to delete personal information if the User(s) have exercised their right to object to processing.
• Object to the processing of the User(s) personal data when We rely on a legitimate interest (or the interest of a third party) and there is something specific to the situation that makes the User(s) object to the processing on this basis. The User(s) also have the right to object if We process personal data for direct marketing purposes, for example, in our recruitment campaigns.
• Request to restrict the processing of personal data of the User(s). This allows the User(s) to request Us to pause the processing of personal data, for example, if the User(s) wants Us to check its accuracy or the reason for processing.
• Submit a request to Us to transfer the User’s personal data to another party.

The User(s) does not need to pay for access to personal data (or for exercising any other rights). However, We may charge a reasonable fee if the User(s)’ request for access is manifestly unfounded or excessive, and in such circumstances We may refuse to grant the request.

We may need to request certain information from the User(s) to help Us verify the identity of the User(s) and to ensure that such User(s) have the right to access the information (or to exercise any other rights of the User(s)). This is another appropriate security measure to ensure that personal data is not disclosed to any person who is not entitled to receive it.

In the event that the User(s) wish to review, verify, correct or request deletion of personal data, object to the processing of personal data or request that We transfer a copy of personal data to another party, please contact Us at [email protected] in writing.

TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

The User’s personal data is transferred to (or within) third countries if the Services provided by Us will also be provided in the territory of a third country. The personal data of the User(s) may also be transferred to entities that provide tax, legal, and audit advice to Us if they operate in or outside the territory of a third country. In each of the above cases, We protect the processing of the User’s personal data, in particular, by entering into confidentiality agreements and processing personal data in a manner that complies with the provisions of generally applicable EU and UK data protection laws, as well as on terms designed to ensure the security of the processing of the User’s personal data. We do not transfer personal data of the User(s) to international organizations. We also do not transfer personal data of the User(s) to third countries, if such transfer is impossible or prohibited by generally accepted legislation.

• Any transfer of personal data to the United States of America and other countries outside the European Union (hereinafter – the “EU”) and the European Economic Area (hereinafter – the “EEA”) will be carried out on the basis of Standard Contractual Clauses (hereinafter – the “Standard Contractual Clauses” or the “SCC”) together with a Transfer Impact Assessment (hereinafter – the “TIA”) in accordance with Art. 46(2)(c) GDPR and with the consent of the User(s), e.g., if the User consents to the use of cookies, this will also be consent to the possible transfer of the User’s personal data to the United States of America in accordance with Art. 49(1)(a) GDPR in connection with Art. 6(1)(a) GDPR.
• Any transfer of personal data to the EU and/or the EEA is carried out on the basis of a Data Protection Agreement (hereinafter referred to as “Data Protection Agreement” and/or the “DPA”), if necessary, together with a TIA, in accordance with Art. 28 GDPR, Art. 32 GDPR, etc., and with the consent of the User(s) (e.g., based on Art. 6(1)(a) GDPR).

Note: By accepting Our Privacy Policy, You agree and authorize Us to transfer Your data as described in this section, subject to applicable law. If You wish to withdraw this authorization, please contact Us at [email protected].

CALIFORNIA RESIDENTS

This section of Our Privacy Policy is dedicated to California residents and serves to supplement the information provided in Our Privacy Policy. It applies exclusively to all visitors, Users, and others who live in California. In the event that the User(s) is a California resident, the User(s) has certain privacy rights under California law, including the California Consumer Privacy Act of 2018 (hereinafter – the “CCPA”).

CATEGORIES OF PERSONAL INFORMATION COLLECTED

We collect personal information that identifies, relates to, or could be reasonably associated with an individual consumer or device. Below are the categories of personal data that we may collect from California residents over the past 12 (twelve) months.

Please keep in mind that the categories and examples listed are based on CCPA definitions. It does not imply that we collect every type of information within these categories, but it reflects our understanding and belief that some of the listed information might have been or may be collected. For example, some data categories may only be gathered if you provide such information directly to us.

• Category A: Identifiers
  Examples: Real name, alias, mailing address, unique personal identifier, IP address, email, account name, driver’s license number, passport number, or other similar identifiers.
• Category B: Personal Information under the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))
  Examples: Name, signature, Social Security number, physical description, telephone number, financial details like bank account, credit or debit card numbers, medical or health insurance information. Some overlap may exist with other categories.
• Category F: Internet or other electronic network activity.
  Examples: Interactions with our website, including browsing behavior, or engagement with our advertising.

SOURCES OF PERSONAL INFORMATION

We gather personal information from various sources, including:

• Directly from You – e.g., when You fill out forms on Our Website.
• Automatically – e.g., through cookies or similar technologies when You browse Our Website.
• Third-party service providers – e.g., from vendors who help us monitor Website usage or provide analytics.

USE OF PERSONAL INFORMATION FOR BUSINESS OR COMMERCIAL PURPOSES

We may use or disclose Your personal data for business or commercial reasons, as outlined by the CCPA, including but not limited to:

• Improving and optimizing Our Website.
• Fulfilling the purposes for which You shared Your information (e.g., responding to an inquiry).
• Compliance with legal obligations or government requests.
• Internal business operations like auditing or detecting security incidents.

If we collect additional personal data categories or change the purpose for which we use Your information, we will update Our Privacy Policy accordingly.

SALE OF PERSONAL INFORMATION

As per the CCPA’s definition, “sell” refers to the transfer or sharing of personal data with third parties for valuable consideration. We do not sell or share Your personal information in exchange for any monetary or other form of value. We also do not disclose Your information to third parties for any form of compensation.

YOUR RIGHTS UNDER THE CCPA

As a California resident, the CCPA grants You specific rights related to Your personal information. These include:

• Right to be informed: You have the right to know what categories of personal information we collect and for what purposes.
• Right to access: You can request details regarding our collection, use, and sharing of Your personal information. Upon verifying Your identity, we will disclose:

• • The categories of personal information we collected about You.
  • The sources from which we obtained the information.
  • The purpose for collecting Your data.
  • The categories of third parties with whom we share Your personal information.

• Right to delete: You have the right to request that we delete Your personal data, subject to certain legal exceptions.
• Right not to be discriminated against: We will not treat You unfairly or deny services for exercising any of Your CCPA rights.

HOW TO EXERCISE YOUR CCPA RIGHTS

To exercise Your rights under the CCPA, You can reach Us via email: [email protected].

You may submit a request on Your behalf, or you can authorize someone else to do so. To process Your request, we may need to verify Your identity and confirm that the personal information pertains to You.

CHILDREN’S PRIVACY

Our Website and Services are not directed to anyone under the age of 18 (hereinafter – the “Children”). We do not knowingly collect personal data from anyone under the age of 18. In case the User(s) is a parent or guardian and knows that Your children have provided Us with the personal data, please contact Us (see “Contact Us” section). If We become aware that We have collected personal data from children without parental consent, We take steps to delete this personal data from Our servers.

APPLICABLE TERMS

Services on the Website: We use User(s) personal data to provide and improve our Services provided on Our Website. By using the Services, the User(s) agree to grant Us full rights to collect, process, use, store, and share such User’s personal data in accordance with this Privacy Policy.

Note: We may partner with third-party companies and individual entrepreneurs to facilitate the operation of our Services, to provide Services on Our behalf, or to assist Us in the analysis of how Our Services and/or Our Website are used for the purpose of improving it, etc. (collectively, “Service Providers”). Such third parties have access to the Personal Data of the User(s) only to perform the tasks provided directly by Us and are obliged not to disclose or use them for any other purpose, except as provided in the customized cooperation agreement (as described below) or in the terms of use (offer agreement) and privacy policy on the websites of such third parties. Such cooperation with third parties must be documented by the necessary documents (including the master service agreement and non-disclosure agreements and/or terms of use (offer agreement) and privacy policy, etc.) with appropriate penalties for breach of obligation, but the User(s) approve by granting Us consent to the processing etc. of personal data that We are not responsible (including solidary responsibility) for the unlawful use of the User’s personal data by such Service Providers (please note that each Service Provider manages personal data in accordance with the personal terms of use (offer agreement) and privacy policy on the Service Providers’ websites).

• Google Analytics (Google LLС) is a web analysis service provided by Google Inc. Google utilizes the data collected to track and examine user behavior, to prepare reports, and share insights with other Google services. Google may use the data collected to contextualize and personalize the advertisements launched via Google’s advertising network. The service is subject to Google’s Privacy Policy (available at the link).
• Google Tag Manager (Google LLС) is a web service designed to optimize the Google Analytics management process. The service is provided by Google Inc. and is subject to Google’s Privacy Policy (available at the link).
• Facebook Ads conversion tracking (Facebook, Inc.) Facebook Ads conversion tracking is an analytics service that binds data gathered from the Facebook advertising network with actions performed on our website. The service is provided by Facebook, Inc. and is subject to Facebook’s Privacy Policy (available at the link).
• Google AdWords Tools (Google AdWords Conversion Tracking/ Dynamic Remarketing / User List / DoubleClick) (Google LLС) Google AdWords conversion tracking and other Google Ads services are analytic instruments, connect data from the Google AdWords advertising network with actions taken on our website. The services are provided by Google Inc. and are subject to Google’s Privacy Policy (available at the link).
• Google AdWords (Google LLC) DoubleClick (Google Inc.) / DoubleClick Bid Manager / Google DoubleClick Google AdWords and Double Click are advertising services that enable efficient interaction with potential customers by suggesting relevant advertisements across Google Search, as well as Google’s partner networks. The services are provided by Google Inc. and are subject to Google’s Privacy Policy (available at the link).
• Facebook Audience Network (Facebook, Inc.) is an advertising service that helps to monitor and evaluate the efficiency of advertising campaigns launched via Facebook. The service is provided by Facebook, Inc., and is subject to Facebook’s Privacy Policy (available at the link).
• LinkedIn Marketing Solutions / LinkedIn Ads (LinkedIn Corporation) LinkedIn Ads allows for tracking the efficiency of advertising campaigns launched via LinkedIn. The service is provided by LinkedIn Corporation and is subject to LinkedIn’s Privacy Policy (available at the link).
• Twitter Advertising / Twitter Conversion Tracking (Twitter, Inc.) The Twitter Ads network allows for tracking the efficiency of advertising campaigns launched via Twitter. The service is provided by Twitter Inc. and is subject to Twitter’s Privacy Policy (available at the link).
• Cloudflare (Cloudflare, Inc.) is a web infrastructure and security service that helps optimize and secure websites by providing protection against DDoS attacks, enhancing site performance, and offering content delivery network (CDN) services. The service is provided by Cloudflare, Inc. and is subject to Cloudflare’s Privacy Policy (available at the link).
• Calendly (Calendly, LLC) is an online scheduling tool that simplifies the process of booking appointments by allowing users to share their availability and automate scheduling. The service is provided by Calendly, LLC and is subject to Calendly’s Privacy Policy (available at the link).
• Google Gmail (Google LLC) is an email service that allows users to send, receive, and organize emails efficiently. It also integrates with other Google services for seamless communication and collaboration. The service is provided by Google LLC and is subject to Google’s Privacy Policy (available at the link).
• Pipedrive (Pipedrive OÜ) is a customer relationship management (CRM) tool designed to help businesses manage their sales processes, track communications, and organize leads. The service is provided by Pipedrive OÜ and is subject to Pipedrive’s Privacy Policy (available at the link).
• Slack (Slack Technologies, LLC) is a collaboration platform that facilitates communication through real-time messaging, file sharing, and integrations with other productivity tools. It is commonly used by teams to streamline workflows and improve internal communication. The service is provided by Slack Technologies, LLC and is subject to Slack’s Privacy Policy (available at the link).

REPORTING A VULNERABILITY

If You have discovered an issue that You believe is an in-scope vulnerability, please email [email protected]. Include the following, as applicable:

• A detailed description of the vulnerability;
• Full URLs associated with the vulnerability;
• A Proof of Concept (POC) or instructions (e.g., screen shots, video, etc.) on how to reproduce the vulnerability, or steps taken to exploit the vulnerability;
• Entry fields, filters, or other input objects involved;
• Your assessment of risk, or exportability assessment;
• Instructions for how to reach You with follow up questions;

Offering a solution is encouraged but not required to report a vulnerability. Lack of detailed vulnerability explanation may result in delays in our response and subsequent potential actions on the finding.

UPDATES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify the User(s) of any changes by posting the new Privacy Policy on this webpage on our Website.

We will notify the User(s) by email and/or post a prominent notice on Our Website before the changes become effective and update the “Last update” at the top of our Privacy Policy.

We recommend that the User(s) periodically review our Privacy Policy for any changes. Updates to this Privacy Policy are effective when they are posted on this page.