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Privacy policy

This Privacy Policy describes how Ericsson AB and other Ericsson Group companies you are contracting or dealing with (“Ericsson”, “us”, “our”, “we”) handle personal data, what your rights are and how you can contact us. This Privacy Policy applies to situations where Ericsson Group companies act as data controllers or equivalent local law concept.  When we refer to “personal data” we mean any information relating to an identified or identifiable individual.

Additional data privacy information may be provided for our websites, events, products, services and any other tools, offerings or platforms that may involve processing of personal data by Ericsson Group companies. Our privacy practices may vary in connection with different products, services, and solutions as well as in different locations in which we operate. We encourage you to read the Privacy Policy of each legal entity and Ericsson website, app, service, or solution you visit, review, use or otherwise interact with, where available.

This Privacy Policy does not apply to Ericsson’s processing activities as processor, for example when we process personal data on behalf of our business customers when we provide services to them. The contracts we have with our customers control how we process personal data in such context. If you are a customer, end-user or employee, or contractor of one of Ericsson’s customers and have questions about the processing of your personal data, we recommend that you contact our respective customer.

We only process personal data in a lawful and fair manner and when permitted to do so. Where required under applicable laws, we rely on one of these legal bases:

  • You have clearly given your voluntary consent to the processing;
  • The processing is necessary for entering into, or performance of a contract to which you are party;
  • The processing is necessary to comply with a legal obligation;
  • The processing is necessary to protect the vital interests of an individual;
  • The processing is necessary for the performance of a task carried out in the public interest; or
  • We, or a third party, have a legitimate interest in using your personal data to achieve the purposes of processing, except where such interests are overridden by your interests or fundamental rights.

Where processing of your personal data is based on your consent, you have the right to withdraw your consent at any time by using the mechanism made available to you or by contacting Ericsson (see the contact details in section 10). Please note that this will not affect processing undertaken prior to the withdrawal of your consent, or any processing based on legal bases other than your consent.

​We only use your personal data where it is necessary for specific purposes. We receive your personal data directly from you, from your employer (e.g., our customer or business partners) or through automated means. Where applicable, we indicate to you in connection with the collection of personal data whether the provision of such data is mandatory. Click the links below to learn more about how we process personal data in different contexts.

We may aggregate your personal data to a non-identifiable format and use such data to improve and develop our services and solutions. Please see also sections 3 and 5 for more general information on how we share and retain your personal data.

Purposes of processing: Why do we process your personal data?

Personal data categories we may process in this context

Legal basis for our processing (where required under applicable laws)

Customer, supplier and partner relationship management and business administration

Ericsson processes personal data about customer, supplier and partner representatives for administrative purposes, contract management and contract performance, sales and sourcing related activities, delivery of products and services, invoicing and management of the services and the business relationship with our customers, suppliers and partners.

We use the relevant personal data to develop our services and to improve the quality of Ericsson’s solutions and services as well as for business planning and customer engagement planning. We also use supplier and partner personal data to perform supplier due diligence and necessary background checks where such checks are required under our policies.  
  • First name, last name
  • Contact details (business email, business phone)
  • Information about your job role (company, business unit, role, office location)
  • Communications with you such as email correspondence
  • Language preferences (e.g., “prefers to use English”)
  • Date of birth where needed
  • Nationality where needed
  • Signatures
  • Other information you may provide, or we may need for the business administration and relationship management purposes
  • Information about supplier representatives collected in connection with potential background checks and supplier due diligence reviews
  • We have a legitimate interest in using your personal data to maintain our business relationships and comply with laws and regulations.

Customer support

Ericsson may process customer representatives’ personal data about how you use our customer support services to provide you with a personalized experience on the customer support platform and to continuously improve the user experience of our services.

We may also process your personal data for troubleshooting and to protect the services, products, and solutions against security and cyber threats and prevent such threats.

Ericsson mainly processes personal data to respond to customer support requests and to provide customer support services as processor on behalf of our customers. Please check the relevant Ericsson business customer’s privacy notice for more information about their processing activities.
  • First name, last name
  • Contact details (business email, business phone)
  • Information on communications with you (call history, chat transcripts, questions, and answers on our Ericsson customer support platforms)
  • Security logs
  • We have a legitimate interest in using your personal data to run our business effectively and efficiently. In certain instances, we may also obtain your consent for certain processing activities.

Ericsson extranet

The Ericsson Extranet portal provides an interface between Ericsson applications and external parties, allowing them to make use of what Ericsson has to offer.

Your personal data is used to issue identity credentials to you to access applications available on the portal, to facilitate access management to the Extranet portal, including providing support and troubleshooting, and to provide you with content that is relevant to you.

We may use your mobile phone number to send you necessary information to change your password. We do not share your mobile number to other companies to use for marketing purposes (on behalf of Ericsson or otherwise).
  • First name, last name
  • Contact details (business email, business phone, mobile phone number)
  • User ID and password
  • IP address
  • Logs and browsing history
  • Information related to the request for access or support
  • We have a legitimate interest in using your personal data to run our business effectively and efficiently.

Customer experience surveys

Ericsson performs customer experience surveys on a regular basis to validate our customers’ needs and to improve and develop our services.
  • First name, last name
  • Contact details (business email)
  • Information about your job role (company, role, country)
  • Your responses to the survey questions
 We have a legitimate interest in developing and improving our services.

Purposes of processing: Why do we process your personal data?

Personal data categories

Legal basis for our processing (where required under applicable laws)

Marketing and communications

If you contact Ericsson with an inquiry, an order, or a request for information or support, we will use this personal data to respond to the inquiry, order, or request and to manage further correspondence.

Ericsson processes personal data for communications on sales and marketing purposes, including email marketing. We may combine this information with data obtained from other sources (such as cookies) to help us improve its overall accuracy and completeness, and to help us better tailor our interactions with you. We also use your data for analytics and service development and service improvement. 

We may use your personal data for lead generation, segmentation, lead nurturing and lead scoring, relationship marketing, cross-selling, and marketing return on investment (ROI) measurement.

Ericsson is also an administrator for certain business pages on social media sites such as Facebook. Ericsson may act as a joint controller with the social media platform provider when processing personal data about the visitors on such page for Ericsson’s advertising purposes, even if Ericsson does not access any personal data. The terms setting forth the data protection obligations and the implementation of data subject rights between Ericsson and Facebook regarding Facebook Insights can be accessed here.
  • First name, last name
  • Contact details (email, business phone)
  • Information about role (company, role, office location)
  • Details about your inquiry, order, or request, (if applicable)
  • Information about contact person at Ericsson
  • Information about marketing opt-in / opt-out
  • Information about “Do Not Sell” choice
  • Information received via cookies if you have given your consent for marketing cookies, such as IP address, device type, and information about your browsing time, browsing history, and interactions with our websites and services
  • Information about your interactions with our marketing communications such as whether you have opened the email or clicked links in our emails
  • You have consented to the processing by giving your consent for email marketing or marketing cookies; or
  • We have a legitimate interest in using your personal data to maintain our business relationship and effectively communicate with our customers.

You may choose not to receive email marketing or communications from us by following the “unsubscribe” instructions included in each email.

You can withdraw your cookie consent any time on our website.

Third-Party Advertising

We use third-party advertising companies to place advertisements on third-party platforms and websites that may be of interest to you based on your behavior on our website and digital services, as well as based on information received from third parties.  These third-party companies might place a cookie in your browser, used for performance measurement (tracking pixel) and cross-device identification.

You can find more information on this in our Cookie Policy. No advertising/marketing cookies are placed on your device if you have not given your consent for using such cookies.
  • IP address
  • Information collected via cookies, such as Client ID, device type and information about your browsing time, browsing history, and interactions with our websites and services, if you have given your consent for analytics and marketing cookies
  • You have consented to the processing by giving your consent for using advertising/marketing and analytics cookies.
You can withdraw your consent any time on our website.

Website analytics, service improvement and service development

We analyze how our website and digital services are being used to make them more intuitive, improve functionality and deliver better content.

We place a cookie in your browser to determine you as returning visitor to our website (random cookie identifier). You can find more information on this in our Cookie Policy. No analytics cookies are placed on your device if you have not given your consent for using such cookies.
  • We may process your IP address for geographic information without storing the IP address.
  • Information collected via cookies such as Client ID, device type and information about your browsing time, browsing history and device type.
  • You have consented to the processing by giving your consent for analytics cookies.
You can withdraw your consent any time on our website.

Surveys and contests

From time to time we may request information from users via surveys or contests. Participation in these surveys or contests is completely voluntary, and the user therefore has a choice whether to disclose this information.

Survey information will be used for purposes of marketing, monitoring, or improving the use and satisfaction of our websites and services. For contests, contact information will be used to register participants, notify the winners and award prizes, etc.
  • First name, last name
  • Contact details (email, business phone)
  • Information about role (company, role, office location)
  • Demographic information (such as gender, age, level of education)
  • Your responses to the survey questions
  • You have consented to the processing; or
  • We have a legitimate interest in using your personal data to develop and improve our services.

Purposes of processing: Why do we process your personal data?

Personal data categories

Legal basis for our processing (where required under applicable laws)

Ericsson events

We process your personal data when you register or attend our or our partners’ online or offline events.

We may use the data collected in connection with our events to send you marketing if we have received your consent for marketing. To learn more about how we process your personal data for marketing purposes, please see section 2.2.
  • First name, last name
  • Contact details (email, business phone)
  • Information about role (company, title, office location)
  • Participation and comments in event sessions and surveys
  • Information about dietary requirements
  • Personal data in the photos and videos taken during the events
  • Information you may provide in feedback or online event chats
  • You have consented to the processing;
  • The processing is necessary to comply with our contractual obligations under the event’s relevant terms and conditions that you may have agreed to; or
  • We have a legitimate interest in using your personal data to develop and maintain our business relationship.

Visitors at Ericsson locations and sites

We register personal data about you if you are visiting our sites or locations for reasons of security and safety of persons and property, as well as for regulatory purposes.
  • First name, last name
  • Contact details (email, business phone)
  • Information about role (company, title, office location)
  • Visiting times (entrance and exit times)
  • We have a legitimate interest in using your personal data to keep track of the visitors and to ensure safety and security in our locations and sites; or
  • The processing is necessary for compliance with a legal obligation.

Camera surveillance

Ericsson uses camera surveillance at Ericsson location and sites where Ericsson conducts business with the purpose to protect our staff, visitors, and company resources and to prevent and discover crime and incidents in the buildings and at sites.
  • CCTV recordings where your images can be identified
  • We have a legitimate interest in using your personal data to enhance safety and security and to protect our resources in our locations and sites.

Your personal data will be accessed by Ericsson personnel on a need-to-know basis. Ericsson shares personal data to other Ericsson Group companies when reasonably necessary for the specific purposes of processing described in this Privacy Policy.

We work with third-party service providers. Such third-party service providers include data management platform providers, data analytics vendors, advertising vendors, customer relationship management software vendors and facility management service providers. These third parties may process your personal data on our behalf as part of providing services for us or they may process the personal data for their own purposes that we have accepted. We limit the information provided to these service providers to what is reasonably necessary for them to perform their functions, and we require them to agree to comply with applicable laws and maintain the confidentiality of such information. We also share your personal data with professional advisors, in our legitimate interests in maintaining our business or as required by a legal obligation, such as with auditors, law firms or accounting firms.

Exceptionally, we may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, to cooperate with law enforcement or other governmental agencies or to otherwise establish, defend or exercise legal claims. We also reserve the right in exceptional circumstances to disclose your personal data that we believe is necessary to take precautions against liability or to protect ourselves, our property, or others from fraudulent, abusive, or unlawful uses or activity.

We may disclose personal data to a prospective buyer, acquirer, successor, seller, new owner, assignee or other relevant third party as necessary when negotiating or in connection with or anticipation of a change of corporate control such as a restructuring, merger, acquisition, sale of assets, bankruptcy, or similar transaction in our legitimate interests to ensure the continued success of our business. 

Since Ericsson Group is present around the world and Ericsson is driving a global business, we may transfer your personal data outside of the country where you are located to Ericsson Group companies and to our contracted service providers or, in limited circumstances, to cooperate with law enforcement or other government agencies located anywhere in the world. The countries where your personal data is transferred may not have similar data protection laws as the country where we collected your personal data. However, Ericsson will protect your personal data as described in this Privacy Policy. 

Transfers outside of the European Economic Area (EEA) and the UK

When transferring your personal data outside of the EEA and the UK, Ericsson will comply with applicable EEA and the UK data protection laws:

  • We may transfer your personal data from the EEA to countries/sectors which the European Commission has found to provide adequate level of data protection in accordance with the GDPR. Information on countries that have been granted with an adequacy decision is available here;
  • We may transfer your personal data from the UK to the countries and territories covered by the UK adequacy regulations. Information on countries covered by the UK Adequacy regulations is available here; and
  • We may rely on our Binding Corporate Rules approved by the European data protection authorities in accordance with the GDPR to transfer personal data intra-group. A copy of our Binding Corporate Rules is available here; and
  • We may rely on all modules of the EU Commission’s Standard Contractual Clauses available here or other appropriate safeguards under the GDPR as well as the UK Addendums to the EU Standard Contractual Clauses and other appropriate safeguards under the UK data protection law.

For more information about how we transfer personal data outside of the country where you are located, you may contact us as specified below in section 10.

Ericsson limits the retention of personal data to a proportionate period during which the personal data is needed to accomplish those purposes or processing the data. When determining the length of time to retain your personal data, we consider various criteria, including whether we need the information to continue to provide you with our services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security, and integrity, or protect ourselves, including our rights, property or products.   

We will also retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies.  The retention period may also depend on legal or regulatory requirements to which Ericsson is subject.

For example, your Extranet login credentials are subject to annual renewal and are deleted in the event of no annual certification. We store your data for marketing and communications purposes for a maximum of 24 months after you last interacted with unless the data is necessary for other purposes of processing. Recorded CCTV material is normally saved for 14 days and a maximum of 60 days for locations with high protection value. Material can be saved for a longer time if needed for legal obligations or as evidence in ongoing legal matter.

When personal data is no longer needed, we have processes in place to securely delete the data, for example by erasing electronic files. Where we aggregate and anonymize your personal data, we may use this information indefinitely.

If you are a U.S. resident, see Section 9 below for information on rights you may have in relation to your personal data. For all other individuals, subject to the applicable data protection laws, you may have the following rights in relation to your personal data:

  • Right to access your personal data. You have the right to obtain confirmation on whether Ericsson processes personal data about you and receive a copy of such data as well as information on how we process your personal data.
  • Right to rectification. You have the right to rectify any inaccurate personal data we process about you or have any incomplete personal data about you completed.
  • Right to erasure. You have the right to have your personal data deleted, if (i) the personal data has been unlawfully processed; (ii) we no longer need such data for the purposes of the processing; or (iii) the processing is based on consent and you withdraw your consent, and we have no other legal basis for processing the data. However, Ericsson will not delete your personal data if Ericsson has a legal obligation to retain the data, the personal data is still necessary for the purposes of processing, or if Ericsson’s legitimate interests override your interests.
  • Right to data portability. You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, and you may have that data ported directly to another controller, where such personal data is processed based on your consent or to perform a contract with you.
  • Right to restriction. You have the right to restrict our processing of your personal data where you believe that the personal data we process is inaccurate or our processing is in unlawful. You may also restrict our processing if Ericsson no longer needs the personal data, but you want us to store the data for the establishment, exercise, or defense of legal claims. You may also require us to restrict the processing of your personal data for the period when we assess your right to object to the processing of your personal data.
  • Right to object. You have the right to object to our processing of your personal data when we rely on our legitimate interests or those of a third party or if we in an exceptional case perform tasks in public interest. If you object to our processing, we will cease processing your personal data end erase the data, unless we can demonstrate compelling legitimate grounds for the processing overriding your interests, or if the data is needed for the establishment, exercise, or defense of legal claims. You always have the right to opt out of receiving direct marketing from us.
  • Right to information. You have the right to receive transparent information about how we process your personal data.
  • Right to withdraw your consent. You have the right to withdraw any consent for processing you provided at any given time. You can withdraw your consent for cookies here. You can withdraw your consent for direct marketing by unsubscribing from receiving our direct marketing. For any other cases, please contact us using the contact details set out in section 10 below. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

For additional information about the rights that may be available to you if you live in certain US states, please see section 9 below.

We will not discriminate against you based on your exercise of any of the rights described above. Please note that a number of these rights only apply in certain circumstances, and all these rights may be limited by law. If you wish to exercise your rights or have any questions regarding the processing of your personal data, please contact us using the contact details set out in section 10 below.

Our products, solutions, or services including our websites are not directed to children under the age of 16, and we do not knowingly collect personal data from children under the age of 16. If you are under 16 years of age, then please do not use or access our services. If we learn that we have collected personal data about persons under 16 years of age and without verifiable parental consent, then we will take appropriate steps to delete this data.

Our websites or services may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our website or services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through our website. We encourage you to learn about third parties’ privacy and security policies before using their services and providing them with information.

If you reside (and depending on where you reside) in the United States, you may also have additional legal rights with respect to your personal data. This Privacy Policy provides a description of such rights and how you may exercise them if they apply to you. Please note that these rights are not absolute, and that in certain cases, we may decline your request as permitted by law, including in the event you reside in a state that does not currently grant you these rights. For information about what categories of personal data we collect, the purposes for collecting and using that information, and what types of service providers we may disclose that information to, please see sections 2 and 3 above.  For purposes of this section, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (or household, as applicable), each as defined by the relevant U.S. state law, and “sell” and “share” have the definitions provided under applicable U.S. law. The laws of certain U.S. states, as applicable, may grant some or all of the following rights to consumers who reside in those states:

  • The right to request that we confirm whether we process data about you and give you access to that information;
  • The right to request information about personal data that we have collected in the 12 months preceding a request – including the categories of information collected, disclosed for a business purpose, and sold/shared, the source of that information, the business purpose of that collection and any selling/sharing, the categories of third parties with whom that information is disclosed or sold/shared, and the specific personal data collected about that particular Customer which information is provided in the table below;
  • The right to receive requested information in a readily usable format if provided electronically;
  • The right to request that we delete any personal data about the consumer that we have collected (although we may be entitled to retain some information for certain purposes);
  • The right to opt out of selling/sharing of personal information to third parties, the disclosure of personal data to third parties for targeted advertising purposes, the processing of personal data for targeted advertising purposes, and/or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects (please click here for instructions on how to opt out of the sale/sharing of your personal data);
  • The right to update or correct any personal data which is out of date or incorrect; and
  • The right to be free from discrimination based on your exercise of your privacy rights.

To exercise your Privacy Rights under this Privacy Policy, please contact us using the contact details set out in section 10 below with the subject line “U.S. Privacy Right Request” and please specify your relationship with Ericsson and which right you wish to exercise in the text of the email. We may need to collect information from you to verify your identity, such as your email address, government issued ID or date of birth, before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. You may also exercise your right to opt out of selling/sharing your data by clicking the “Do Not Sell or Share My Personal Information” button on the footer of our website.

Your browser settings may allow you to transmit a “do not track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of your information when you visit various websites.  To learn more about “do not track” signals, you can visit http://www.allaboutdnt.com/.  The Ericsson websites respond to the Global Privacy Control signal. You can turn on the Global Privacy Control (GPC) to opt out of the “sale” or “sharing” of your personal data that is browser based for each browser system that you use. Please note that not all browsers participate in the GPC. Learn more at the GPC here.  For more information on how we use cookies, please see our Cookie Policy.

In addition, you may have the right to appeal our decision regarding a request related to these rights by contacting us using the information provided below in section 10. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

Notice to Residents of California

Pursuant to the California Consumer Privacy Act (“CCPA”), Ericsson is a service provider with respect to personal data it processes on behalf of its customers in its provision of services to its customers, but a business with respect to the categories of personal data described in Section 2.  For purposes of this section, references to “personal data” shall include “sensitive personal information” as that term is defined under the CCPA.

If you are a former California employee and would like to exercise your rights with respect to personal data we collected in the course of your employment, please contact us using the contact details set out in section 10 below with the subject line “California Former Employee Data Request”

In the last 12 months, we have collected and disclosed for a business purpose the following categories of personal data and sensitive personal information (denoted by *) about California residents:

 

Category of personal data (corresponds to categories listed in California Consumer Privacy Act §1798.140(v)(1))

Examples

Categories of Recipients
Category A: Identifiers Name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. Affiliates, partners, service providers,
Category B: personal data listed in § 1798.80 of the California Customer Records statute A name, signature, address, telephone number, employment, billing and transactions information. Affiliates, partners, service providers
Category C: Characteristics of protected classifications under California or federal law Age, ethnicity,* race,* languages spoken, or gender.  To the extent these characteristics are voluntarily disclosed to us or contained in any content transmitted across or stored on our networks. Affiliates, partners, service providers
Category D: Commercial Information Records and history of products or services purchased or considered. Affiliates, partners, service providers
Category F: Internet or other electronic network activity information Interaction with our websites, applications, or advertisement, such as browsing history, search history, and related information. Affiliates, partners, service providers

Category G: Geolocation data

 Approximate physical location (derived from an Internet Protocol address) Affiliates, partners, service providers
Category H: Audio, electronic, visual, thermal, olfactory, or similar information Recordings of any phone or video calls between you and Ericsson (if separately notified or agreed on), CCTV recordings Affiliates, partners, service providers
Category I: Professional or employment-related information Job title, employer name. Affiliates, partners, service providers

 

Categories of “sensitive personal information”
Examples of data Categories of recipients
Login credentials, the contents of a resident’s email, and chat messages in connection with customer support, and government identifiers Affiliates, partners, service providers

 

We may have disclosed this personal data to Ericsson Group affiliates, partners, and service providers for the business or commercial purposes set out in section 3 above. We only use and disclose sensitive personal information for the purposes specified in the CCPA. The criteria we use to determine how long to retain your personal data is described in Section 5 above.

We do not have actual knowledge that we sell/share personal data of residents under 16 years of age. However, we do share, and have in the preceding 12 months shared, the following categories of personal data about California residents with third parties for targeted advertising purposes:

 

Category of personal data

Categories of Recipients
IP address Marketing platform providers, data brokers
Information collected via cookies, such as Client ID, device type and information about your browsing time, browsing history, and interactions with our websites and services, if you have given your consent for analytics and marketing cookies Marketing platform providers, data brokers

 

Pursuant to the rights set forth in this Section 9 above, California residents have the right to opt out of the sharing of their personal data for targeted advertising using the methods described in this section 9  (you can click here for instructions on how to opt out of the sale/sharing of your personal data) or by contacting Ericsson using contact details in section 10.

If you have any questions or a complaint pertaining to your personal data you can also contact the Group Data Protection Officer by mail at Ericsson AB, Group Function Legal Affairs, 164 80 Stockholm, Sweden or you can send an e-mail to ericsson.group.privacy@ericsson.com.

It is also possible to contact a local Data Protection Officer in your country. You can find the respective contact details here. If you have further concerns about the processing of your personal data, you may also file a formal complaint with the competent supervisory authority in your country.

Ericsson may, from time to time, make changes to this Privacy Policy to reflect any changes in our data processing practices. We recommend that you visit this Privacy Policy on occasion to learn about new privacy practices or changes.  If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you by means consistent with applicable law and will take additional steps as required by applicable law.

This Privacy Policy was last updated: September 22, 2023.