Version: 10.02.2022

The protection of your personal data is very important to us. As such, our customers’ and users’ data protection and data security is a top priority for Sedo GmbH (hereinafter referred to as “Sedo”). When you use a Sedo website, we will collect personal data relating to you for various purposes. Your personal data is processed in accordance with the EU General Data Protection Regulation and the applicable country-specific data protection regulations.

 Sedo has taken technical and organizational measures to guarantee the greatest possible protection of the personal data collected and processed via this website. Notwithstanding this, internet-based data transfers are generally subject to security weaknesses, making it impossible to absolutely guarantee your protection. For this reason, all data subjects are free to visit the Sedo website and send your personal data to us using alternative, non-electronic means.

1. Definitions

Our data protection declaration is based on the terms used by the European legislator for the adoption of the EU General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

f) Pseudonymization

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the controller

We, Sedo GmbH, are the controller within the meaning of the European GDPR, that is the legal person which determines the purposes and means of the processing of personal data. Our contact details are: Im Mediapark 6B, 50670 Cologne, Germany; Ph.: (+49) 221 / 340 30 – 230; Fax: (+49) 221 / 340 30 – 102, email: kontakt<at>sedo.com

3. How to contact the data protection officer

All data subjects may refer personal data-related questions or queries to our data protection officer directly. Possible contact options are: Sedo GmbH, Im Mediapark 6B, 50670 Cologne, Tel.: (+49) 221 / 340 30 – 230, e-mail: dataprotection<at>sedo.com.

4. How is your personal data processed?

a) Collection of general data and information

When you visit our website our servers temporarily save all accesses in a log file. The following information is temporarily stored (until it is automatically deleted after six months):

• The requesting device’s IP address
• Date and time accessed
• File requested by the client (file name and URL)
• Data volume transferred
• Indication if access was successful
• Recognition data regarding the browser and operating system used.

When this general data and information is processed, we do not connect it to a data subject. Rather, this information is processed to allow access to the website (establishing a connection), for the purposes of the ongoing technical functionality of our IT systems and the technology in our website, for system security and to optimize our online offerings. As such, the data and information are analyzed by us for statistical purposes on the one hand and, on the other hand, to improve our company’s data protection and data security and thereby to offer an optimal level of data protection in relation to the personal data processed by us. The data on the server log files is kept separate from personal data provided by a data subject.

Personal data going beyond this, such as name, address, telephone number or email address are not collected unless you provide this information voluntarily, for example in the context of a request for information.

b) Contact possibility

Our website contains information that enables a quick electronic contact 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, 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.

The processing of the transmitted data is based on Art. 6 para. 1 p. 1 lit. f) DSGVO in order to protect our legitimate interests.

5. Cookies

To improve the user experience on our website and enable you to use certain features, some pages of this website make use of cookies. These are small text files which are stored on your computer. Most of the cookies we use are deleted from your hard drive when you end the browser session (so-called session cookies). Other cookies remain on your computer and allow us to recognize your computer the next time you visit our website (so-called persistent cookies). Our partner companies are not allowed to process personal data collected via our website using cookies.

You can prevent cookies from being stored on your hard drive by changing your browser settings to “do not accept cookies”. You can also configure your browser so that it asks you whether to accept or reject the cookies before they are placed. You are also always able to delete cookies once they have been saved. For detailed instructions please refer to your browser or device user manual. Disabling cookies may limit your access to some features of our website in some cases. You can find further information on our cookies in our cookie policy.

Cookies which are necessary to carry out electronic communication or to provide certain functions requested by you (e.g. shopping cart functions) are stored pursuant to art. 6 para. 1 p. 1 lit. f) of the GDPR. Website operators have a legitimate interest in storing cookies for the purposes of optimizing the provision of their services free of technical errors. If other cookies (e.g. Cookies analyzing your surfing behavior) are stored, they will be covered separately in this privacy policy.

6. Information that we automatically receive based on your use of our websites

When you use our services or visit our website, we automatically collect data regarding your use or your visit. We do this using various tracking technologies. On the one hand, we collect user and third-party data on our server. On the other, we use cookies, pixels and similar tracking technologies on devices.

a) Data protection provisions about the application and use of Google analytics (with anonymization function)

On our website we have 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.

For the web analytics through Google Analytics we use the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

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 us 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 of 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 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 www.google.com/intl/en/policies/privacy/ and under www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link www.google.com/analytics/.

The tracking and the associated analysis of user behavior are principally carried out for the performance of our contractual obligations. This processing of personal data is carried out pursuant to art. 6 para. 1 p. 1 lit. b) of the GDPR. You are able to prohibit third party provider tracking.

Google Analytics also uses tracking technology to measure the success of advertising campaigns and optimize the display of advertising. This processing of personal data is carried out pursuant to art. 6 para. 1 p. 1 lit. f) of the GDPR. You are able to prohibit third party provider tracking.

b) Data protection provisions about the application and use of Google Remarketing

As a further tracking-technology we have integrated Google Remarketing services on our website. Google Remarketing is a feature of Google AdWords, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise’s Internet site. The integration of Google Remarketing therefore allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.

The operating company of the Google Remarketing services is the Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users.

Google Remarketing sets 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 enables a recognition of the visitor of our website if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During the course of this technical procedure, Google receives personal information, such as the IP address or the surfing behavior of the user, which Google uses, inter alia, for the insertion of interest relevant advertising.

The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is 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 from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google 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 the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser used by the data subject.

Further information and the actual data protection provisions of Google may be retrieved under www.google.com/intl/en/policies/privacy/.

Google Remarketing also uses tracking technology to measure the success of advertising campaigns and optimize the display of advertising. This processing of personal data is carried out pursuant to art. 6 para. 1 p. 1 lit. f) of the GDPR. You are able to prohibit third party provider tracking.

c) Taboola

We use the Taboola service on our website, which makes it possible to play out user-specific recommendations for content and ads based on surfing behavior and customer interests in order to improve the user-friendliness of our offering. The usage profiles are created using pseudonyms, they are not merged with the data about the bearer of the pseudonym and do not allow any conclusions to be drawn about personal data. Taboola collects the following user information by means of cookies:

(1) events from the user’s website including (a) initial and subsequent page visits to our website; (b) conversion data; (c) the associated hashed Taboola User ID read from the cookie; (d) engagement signals (time on site, scroll depth, session depth); (e) hashed emails (if provided by the user); and (f) gender of the user (if provided by the user); and (2) information about the user’s browser read from the user agent, including operating system, browser type, and browser version.

For more information about Taboola, please visit www.taboola.com/privacy-policy.

There you can deactivate tracking at any time in the “User Choices” section.

Your data is processed exclusively based on your consent (Art. 6 para. 1 p. 1 lit. a) of the GDPR). You can revoke this consent at any time by deactivating the tracking. After you have opted out, no more personalized content/advertising will be played to you.

d) Use of plugins from social media providers

We use plugins from social media (Facebook and Twitter) on this website. You can usually recognize the plugins by the respective social media logos. To ensure data protection on this website, we only use these plugins together with the so-called “Shariff” solution. The integration via Shariff prevents the integrated plugins from transmitting data to the respective social media provider the first time you enter the detail page on our website. Only when you activate the respective plugin by clicking the associated button, a direct connection to the provider’s server is established. Only then does the respective social media provider receive the information that you have visited this website with your IP address. If you are logged into your respective social media account (e.g. Facebook) at the same time, the respective provider can assign your visit to this website to your user account. Activating the plugin constitutes consent within the meaning of Art. 6 (1) p. 1 lit. a) GDPR. You may revoke this consent vis-à-vis the respective social media provider at any time with effect for the future.

We use services of the following social media providers:

aa) Twitter

On our pages, we use plugins of the provider Twitter Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA 1355 Market Street, Suite 900, San Francisco, CA 94103, USA (Twitter). By activating the button “share tweet” – you can draw the attention of other members of the network to pages you have visited. The button is integrated by means of the Shariff solution described above, so that personal data is only collected by the provider Facebook when the button is activated. We have no influence on the type and scope of the further collection of personal data. Information on data protection at Twitter is available at https://twitter.com/de/privacy.

bb) Facebook

On our pages, we use plugins from the provider Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA (Facebook). By activating the button “f – share” – you can draw the attention of other members of the network to pages you have visited. The button is integrated by means of the Shariff solution described above, so that personal data is only collected by the provider Facebook when the button is activated. We have no influence on the type and scope of the further collection of personal data. Facebook Ireland (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) is responsible for data processing. You can find more information on data processing at Facebook at https://www.facebook.com/policy.php.

7. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

8. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, if it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

9. Data security

We have taken technical and organizational measures to protect your personal data from loss, destruction, forgery, manipulation and unauthorized access or disclosure. All our employees and other persons involved with the data processing are under an obligation to treat personal data with confidentiality and in accordance with data protection-relevant laws.

10. Links to third-party websites

If you use external links which are featured on our websites, our privacy policy does not extend to these links. We do not have any influence over the third parties’ compliance with data protection and security requirements and refer you to the relevant providers’ privacy policies.

11. Rights of the data subject

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact us.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
• the existence of the right to lodge a complaint with a supervisory authority;
• where the personal data are not collected from the data subject, any available information as to their source;
• the existence of automated decision-making, including profiling, referred to in Article 22 para. 1 and para. 4 of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact us.

c) Right of rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Considering the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact us.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, if the processing is not necessary:

• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
• The data subject withdraws consent to which the processing is based according to point (a) of Article 6 para. 1 of the GDPR, or point (a) of Article 9 para 2 of the GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Article 21 para. 1 of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 para 2 of the GDPR.
• The personal data have been unlawfully processed.
• The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data have been collected in relation to the offer of information society services referred to in Article 8 para. 1 of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by us, he or she may, at any time, contact us. We will ensure that the erasure request is complied with immediately.

Where we have made personal data public and we are obliged pursuant to Article 17 para. 1 to erase the personal data, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. We will arrange the necessary measures in individual cases.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from us restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
• The data subject has objected to processing pursuant to Article 21 para. 1 of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by us, he or she may at any time contact us. We will arrange the restriction of the processing.

f) Right of data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, if the processing is based on consent pursuant to point (a) of Article 6 para. 1 of the GDPR or point (a) of Article 9 para. 2 of the GDPR, or on a contract pursuant to point (b) of Article 6 para. 1 of the GDPR, and the processing is carried out by automated means, if the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20 para. 1 of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact us.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6 para. 1 p. 1 of the GDPR. This also applies to profiling based on these provisions.

We shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If we process personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects the processing for direct marketing purposes, we will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact us. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, we will implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on our part, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact us.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact us.

j) Contact

If you wish to exercise one of your rights mentioned under section 11 a) – i) you can contact us under privacy<at>sedo.com.

12. Amending our privacy policy

We reserve the right to amend or adjust our security and or privacy policy as made necessary by technological or regulatory developments. In these cases, we will also amend our information on data protection. Please be sure to take note of the most recent version of our privacy policy.