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The term "website" refer to website salest.io and it subdomains, including but not limited to app.salest.io, operated and managed by Jetlic UG (haftungsbeschränkt).
The following privacy policy applies to the use of the website and services from
Jetlic UG (haftungsbeschränkt)Werinherstraße 3
81541 München
Germany
represented by the managing director Oleksandr Otchenashev and informs users about the collection, processing and use of personal data. Personal data are individual details about personal or factual circumstances of a specific or identifiable natural person.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Jetlic UG (haftungsbeschränkt)
Jetlic UG (haftungsbeschränkt) has implemented numerous technical and organizational measures to ensure the complete protection of personal data processed through this website. It should be noted that data transmission over the Internet can have security gaps. An absolute protection may not be guaranteed.
This site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. User can recognize an encrypted connection in they browser's address line when it changes from "http://" to "https://" and the lock icon is displayed in they browser's address bar. If SSL or TLS encryption is activated, the data they transfer to Jetlic cannot be read by third parties.
The collection, use or processing of personal data by the Jetlic UG (haftungsbeschränkt) only takes place if this is permitted by law, required to execute contractual relationship or if the user consents to the collection of data.
The data will only be passed on to third parties if this is necessary and to process specific inquiries and contractual relationships.
For technical reasons, the website and services of the Jetlic UG (haftungsbeschränkt) collect a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files.
This access data includes:
This data is anonymous and is stored separately from any personal data you may have provided. It is not possible to draw conclusions about a specific person. The evaluation is evaluated for statistical purposes. For the justified suspicion of illegal use, the Jetlic UG (haftungsbeschränkt) reserves the right to subsequently check this data.
We collect, process, and use personal data only insofar as it is necessary to establish, or modify legal relationships with us (master data). This is done based on Art. 6 (1) (b) of the GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract. We collect, process and use your personal data when accessing our website (usage data) only to the extent required to enable you to access our service or to bill you for the same. Collected customer data shall be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.
We transmit personally identifiable data to third parties only to the extent required to fulfill the terms of your contract, for example, to companies entrusted to deliver goods to your location or banks entrusted to process your payments. Your data will not be transmitted for any other purpose unless you have given your express permission to do so. Your data will not be disclosed to third parties for advertising purposes without your express consent. The basis for data processing is Art. 6 (1) (b) of the GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
We transmit personally identifiable data to third parties only to the extent required to fulfill the terms of your contract with us, for example, to banks entrusted to process your payments. Your data will not be transmitted for any other purpose unless you have given your express permission to do so. Your data will not be disclosed to third parties for advertising purposes without your express consent. The basis for data processing is Art. 6 (1) (b) of the GDPR, which allows the processing of data to fulfill a contract or for measures preliminary to a contract.
Jetlic UG (haftungsbeschränkt) website includes content from third parties. These can be e.g. YouTube videos or graphics of other websites. In such a case, the third party provider uses your IP address to enable the display of this content.
Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Users of this website have the opportunity to contact the provider (for example via a contact form or by e-mail). In the event of contact, the provider stores the user's details for the purpose of processing the inquiry and in the event of follow-up questions. The data will not be passed on to third parties.
The website of the Jetlic UG (haftungsbeschränkt) contains information that enables contact electronic to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject.
With the newsletter, the Jetlic UG (haftungsbeschränkt) website and services send information about individual offers.
If users would like to receive the newsletter, an e-mail address is required. This e-mail address will be checked to see if the user is also the owner/authorized user of the e-mail address. The data will only be used for sending the newsletter and will not be passed on to third parties. Further data will not be collected.
When registering to receive the newsletter, the IP address and the date of registration are stored. The storage serves exclusively as security in the event that a third party has misused the address and has registered for the newsletter without the knowledge of the owner or authorized person.
The consent to the storage of the data and their use can be revoked at any time via a link in the newsletter itself, in the profile area or by notifying the above-mentioned contact options.
The Internet pages of the Jetlic UG (haftungsbeschränkt) use cookies. Cookies are text files that are stored in a computer system via an Internet browser. Most cookies are so-called "session cookies" which are deleted after the end of the visit. In individual cases, however, these cookies provide information in order to automatically recognize the user. Cookies serve to improve the user-friendliness of the website and to collect statistical data on the use of the website.
Through the use of cookies, the Jetlic UG (haftungsbeschränkt) can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
If users do not agree to the use of cookies, it is possible to restrict or completely deactivate their use in the browser settings. In the event that the use of cookies is restricted or deactivated, the use of this website may be restricted.
With using Jetlic UG (haftungsbeschränkt) ebay Integration services (that included but not limited services PrestaBay — ebay Integration, PrestaBay — ebay Import, Salestio — Shopify eBay Integration, Salestio — eBay Integration) we store your ebay token together with your ebay account it. This information passed to eBay Inc., with offices located at 2145 Hamilton Avenue, San Jose, CA 95125 each time that you transact with them. You may always remove or un-authorize your Jetlic UG (haftungsbeschränkt), eBay Token by visiting your "my eBay" directly on eBay.com and going through the un-authorization process.
Jetlic UG (haftungsbeschränkt) may share your basic account information with eBay, which may result in eBay contacting you. The data which we may share is the following:
Reasons for sharing this information include, but are not limited to; promotional efforts, account support, general eBay support and/or overall selling guidelines.
Every time we share this information with ebay we ask your permission via one of our support channels.
For providing ebay integration services by Jetlic UG (haftungsbeschränkt) may temporarily store not-personal information about ebay listings, scheduled ebay operations. Jetlic UG (haftungsbeschränkt) does not save and does not store any personal information about ebay buyer in logs.
To offer ebay order management & order importing functionality, our website may save ebay sales information in DB server. Access to this information possible only by authorized ebay seller (merchant) for whom this data was downloaded. You could disable this functionality by deactivating order importing function inside settings. Based on configuration settings orders information may be imported to merchant online store (Shopify or Bigcommerce). After 30 days from orders import date all personal information about buyer removed and are made unavailable for the further identification of the buyer.
Jetlic UG (haftungsbeschränkt) calculates the anonymous statistic for every merchant used ebay services. This statistic includes the name of ebay marketplace, the name of the operation, operation status (or value). These statistics collected for general operation with items and for ebay sales. Statistics collecting required for correctly differentiate Jetlic UG (haftungsbeschränkt) customers in different application packages and successfully execute the contract.
With using Jetlic UG (haftungsbeschränkt) amazon Integration services (that included but not limited services PrestaBay — amazon Integration, PrestaBay — amazon Import, Salestio — Amazon Integration, Salestio — Shopify Amazon Integration, Salestio — Bigcommerce Amazon Integration) we store your amazon seller id, amazon auth token together with provided by you amazon account name. This information passed to Amazon Europe Core SARL, Amazon EU SARL, Amazon Services Europe SARL, Amazon Media EU SAR, Amazon.com with registered address at Inc 410 Terry Ave N SEATTLE WA 98109-5210 each time that you transact with them. You may always remove or un-authorize your access to Jetlic UG (haftungsbeschränkt), by visiting your amazon seller central account in corresponding amazon website and going through the un-authorization process.
Jetlic UG (haftungsbeschränkt) may share your basic account information with Amazon, which may result in Amazon contacting you. The data which we may share is the following:
Reasons for sharing this information include, but are not limited to; promotional efforts, account support, general Amazon support and/or overall selling guidelines.
Every time we share this information with Amazon we ask your permission via one of our support channels.
For providing amazon integration services Jetlic UG (haftungsbeschränkt) may temporarily store not-personal information about amazon listings, scheduled amazon operations. Jetlic UG (haftungsbeschränkt) does not save and does not store any personal identification information in logs.
To offer amazon order management, order importing, shipping fulfillment, tax management functionality, our webiste may save amazon order information in DB server.
Access to order information is possible only by authorized amazon seller for a purpose of performing order fulfilment, tax & shipping operations. Amazon sellers could disable this functionality by deactivating order importing function inside website. Based on configuration settings orders information may be imported to merchant online store (Shopify or Bigcommerce). After 30 days from orders sale date all buyer personal information are removed and orders made unavailable for the further identification of the buyer.
Jetlic UG (haftungsbeschränkt) calculates an anonymous statistic for every user used amazon services. This statistic includes the name of amazon marketplace, the name of the operation, operation status (or value). These statistics collected for general operation with items and for amazon sales. Statistics collecting required for correctly differentiate Jetlic UG (haftungsbeschränkt) customers in different website packages.
On this website, applications of the support platform Help Scout Inc., 100 City Hall Plaza 5th Floor Boston, MA 02108 are integrated.
The Helpscout widget can be recognized by the special support form where the user need to enter email and support questions.
When contacting us via email prestabay@involic.com, support@salest.io or started support widget, widget receives the information that the user was submitted for receive support. Further information can be found in the Help Scout privacy policy at https://www.helpscout.com/company/legal/privacy/
On this website, the Jetlic UG (haftungsbeschränkt) provides apps to Shopify merchants to power their Shopify store(s).
When user install the App, website are automatically able to access certain types of information from your Shopify account:
read_customers,write_customers
Access to Customer and Saved Search.
read_products,write_products
Access to Product, Product Variant, Product Image, Collect, Custom Collection, and Smart Collection.
read_orders,write_orders
Access to Order, Transaction and Fulfillment.
read_locations
Access to Location.
read_inventory,write_inventory
Access to Inventory Level and Inventory Item.
write_fulfillments,read_fulfillments,read_assigned_fulfillment_orders,write_assigned_fulfillment_orders
Access to Fulfillment Service.
Information about you and others who may access the App on behalf of your store, such as your name, address, email address, phone number, and billing information.
We collect personal information directly from the relevant individual, through your Shopify account, or using the following technologies: “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
On this website, the Jetlic UG (haftungsbeschränkt) has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
This website uses this service to continuously optimize the website for visitors and not to obtain personal information about visitors. Data protection is taken very seriously and therefore the function: "_anonymizeIp ()" is used, which automatically truncates the IP addresses by the last four digits and prevents them from being assigned to a single visitor.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits to our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
Our website uses Google Conversion Tracking. If you have reached our website via an advertisement sent by Google, Google Adwords will set a cookie on your computer. The conversion tracking cookie is set when a user clicks on a Google-served ad. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages on our website and the cookie has not expired, we and Google may recognize that the user clicked on the ad and was redirected to this page. Each Google AdWords customer receives a different cookie. Cookies cannot be tracked through AdWords advertisers' websites. The information gathered using the conversion cookie is used to Conversion statistics for AdWords advertisers who have opted for conversion tracking. Customers are told the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users.
If you do not want to participate in the tracking, you can refuse the required setting of a cookie - for example via a browser setting that generally disables the automatic setting of cookies or sets your browser to block cookies from the domain "googleleadservices.com".
Please note that you can not delete the opt-out cookies as long as you do not want to record measurement data. If you have deleted all your cookies in the browser, you must set the respective opt-out cookie again.
This website uses Google Inc.'s remarketing feature. This feature is designed to present interest-based ads to website visitors within the Google Network. A so-called "cookie" is stored in the browser of the website visitor, which makes it possible to recognize the visitor when he or she visits websites that belong to the advertising network of Google. On these pages, visitors may be presented with ads related to content that the visitor previously viewed on web pages using Google's remarketing feature.
Google says it does not collect any personal information during this process. However, if you still do not want Google's Remarketing feature, you can always disable it by making the appropriate settings at http://www.google.com/settings/ads. Alternatively, you can disable the use of cookies for interest-based advertising through the Network Initiative by following the instructions at http://www.networkadvertising.org/managing/opt_out.asp.
On this website, the Jetlic UG (haftungsbeschränkt), use the web analysis service Hotjar of Hotjar Ltd. Hotjar Ltd. is a European company based in Malta (Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Tel: +1 (855) 464-6788).
This tool allows you to track movements on the websites where Hotjar is used (so-called heat maps). For example, you can see how far users scroll and which buttons users click on how often. Furthermore, the tool also makes it possible to obtain feedback directly from the users of the website. In this way, we obtain valuable information to make our websites even faster and more customer-friendly.
Through Hotjar, we can only track which buttons are clicked, the mouse's path, how far it scrolls, the screen size of the device, device type and browser information, geographic location (country only), and the preferred language to display our website. Areas of the websites where personal information about you or third parties is displayed are automatically hidden by Hotjar and therefore cannot be traced at any time. Hotjar offers each user the possibility to prevent the use of the Hotjar tool by means of a "Do Not Track" header, so that no data about the visit of the respective website is recorded. This is a setting that is supported by all common browsers in current versions. To do this, your browser sends a request to Hotjar to deactivate the tracking of the respective user. If you use our websites with different browsers/computers, you must set up the "Do Not Track Header" for each of these browsers/computers separately.
Detailed instructions with information about your browser can be found at: https://www.hotjar.com/opt-out
Further information about Hotjar Ltd. and about the Hotjar tool can be found at: https://www.hotjar.com
The Hotjar Ltd. privacy policy can be found at: https://www.hotjar.com/privacy
This website and application (app.salest.io) uses the services of Campaign Monitor to send newsletters. This service is provided by Campaign Monitor Pty Ltd, 201 Elizabeth Street, Sydney NSW 2000, Australia.
Campaign Monitor is a service which organizes and analyzes the distribution of newsletters. If you provide data (e.g. your email address) to subscribe to our newsletter, it will be stored on Campaign Monitor servers in the USA and Australia.
We use Campaign Monitor to analyze our newsletter campaigns. When you open an email sent by Campaign Monitor, a file included in the email (called a web beacon) connects to Campaign Monitor's servers. This allows us to determine if a newsletter message has been opened and which links you click on. In addition, technical information is collected (e.g. time of retrieval, IP address, browser type, and operating system). This information cannot be assigned to a specific recipient. It is used exclusively for the statistical analysis of our newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to your interests. Further information on data analysis by Campaign Monitor can be found here: https://www.campaignmonitor.com/resources/guides/reporting/.
If you do not want your usage of the newsletter to be analyzed by Campaign Monitor, you will have to unsubscribe from the newsletter. For this purpose, we provide a link in every newsletter we send. You can also unsubscribe from the newsletter directly on the website.
Data processing is based on Art. 6 (1) (a) of the GDPR. You may revoke your consent at any time by unsubscribing to the newsletter. The data processed before we receive your request may still be legally processed.
The data provided when registering for the newsletter will be used to distribute the newsletter until you cancel your subscription when said data will be deleted from our servers and those of Campaign Monitor. Data we have stored for other purposes (e.g. email addresses for the members area) remains unaffected.
For details, see the Campaign Monitor privacy policy at https://www.campaignmonitor.com/policies/#privacy-policy.
We have entered into a data processing agreement with Campaign Monitor, in which we require Campaign Monitor to protect the data of our customers and not to disclose said data to third parties.
On this website, the Jetlic UG (haftungsbeschränkt) has integrated components of the enterprise Facebook. Facebook is a social network.
A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.
If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the "Like" button, “Chat” or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.
Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.
The data protection guideline published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.
On this website, the Jetlic UG (haftungsbeschränkt) has integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called ‘tweets,’ e.g. short messages.
The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.
If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.
Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made.
The applicable data protection provisions of Twitter may be accessed under https://twitter.com/privacy?lang=en.
If you would like to access, review, update, rectify, or delete any Personal Information we hold about you, or exercise any other data subject right available to you under the EU General Data Protection Regulation (GDPR) you can send email to privacy@jetlic.com with request details.
Our Privacy team will examine your request and respond to you as quickly as possible! Some information may remain in our records after the deactivation of your account. Please note that we may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
The Internet pages and services of the Jetlic UG (haftungsbeschränkt) are not intended for children under the age of 18, and we do not knowingly collect personal information from users in this age group.
Jetlic UG (haftungsbeschränkt) keep your information in data centers within the European Union. For technical reasons, our application vendors may transfer your data to countries outside the European Economic Area. When this is the case, we use appropriate safeguards, namely the European Commission’s standard contractual clauses and Privacy Shield.
We adhere to the principles of data avoidance and data economy. Therefore, we only store your personal data for as long as is necessary to achieve the purposes mentioned here or as provided for by the various storage periods provided for by law. After discontinuation of the respective purpose or expiration of these deadlines, the corresponding data will be routinely and in accordance with the statutory provisions blocked or deleted.
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to privacy@jetlic.com, and we will try to resolve your concerns.
We keep our privacy policy under regular review and we will place any updates on this webpage. This privacy policy was last updated on 16 February 2021.