Privacy Policy

This Privacy Notice explains our approach on how we collect personal information about visitors of our website, how we use it, disclosure conditions to others and security provisions.

INTRODUCTION

Welcome to ExalensCyberlens Ltd’s (trading as Exalens) privacy policy.

Cyberlens Ltd (company number 09562835) Exalens respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when (i) you visit our website  (regardless of where you visit it from); (ii) how we look after your personal data when you disclose the same when communicating with us; and (iii) tell you about your privacy rights and how the law protects you.

This website is not intended for children and we do not knowingly collect data relating to children.

1 IMPORTANT INFORMATION AND WHO WE ARE

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Exalens is the controller and responsible for your personal data (collectively referred to as “Exalens”, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the [DPO OR data privacy manager] using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Cyberlens Ltd

Email address: info@cyberlens.com

Postal address: Kastanjelaan 400,Eindhoven, 5616 LZ

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2 THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, job titles (where an individual can be identified by the same), date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3 HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

· Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;

• arrange a demo for our products or services;

• create an account on our website;

• subscribe to our service or publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

· Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

· Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data from the following parties:

o analytics providers such as Google based outside the UK;

o advertising networks  based inside and outside the UK; and

o search information providers  based inside and outside the UK.

· Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

· Identity and Contact Data from data brokers or aggregators.

· Identity and Contact Data from publicly available sources (if applicable).

· Third party marketing agencies (we will notify you where we use these agencies).

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4) HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

To register you as a new customer

Type of data:
  • a) Identity
  • b) Contact
Lawful basis for processing including basis of legitimate interest:
  • a) Performance of a contract with you

To process and deliver your order including:

  • a) Manage payments, fees and charges
  • b) Collect and recover money owed to us
Type of data:
  • a) Identity
  • b) Contact
  • c) Financial
  • d) Transaction
  • e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
  • a) Performance of a contract with you
  • b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

  • a) Notifying you about changes to our terms or privacy policy
  • b) Asking you to leave a review or take a survey
Type of data:
  • a) Identity
  • b) Contact
  • c) Profile
  • d) Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
  • a) Performance of a contract with you
  • b) Necessary to comply with a legal obligation
  • c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

Type of data:
  • a) Identity
  • b) Contact
  • c) Profile
  • d) Usage
  • e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
  • a) Performance of a contract with you
  • b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data:
  • a) Identity
  • b) Contact
  • c)Technical
Lawful basis for processing including basis of legitimate interest:
  • a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data:
  • a) Identity
  • b) Contact
  • c) Profile
  • d) Usage
  • e) Marketing and Communications
  • f) Technical
Lawful basis for processing including basis of legitimate interest:
  • Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data:
  • a) Technical
  • b) Usage
Lawful basis for processing including basis of legitimate interest:
  • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods products or services that may be of interest to you

Type of data:
  • a) Identity
  • b) Contact
  • c) Technical
  • d) Usage
  • e) Profile
  • f) Marketing and Communications
Lawful basis for processing including basis of legitimate interest:
  • Necessary for our legitimate interests (to develop our products/services and grow our business)

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MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.exalens.com/cookie-policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5 DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

· Internal Third Parties include other companies within the Exalens Group who may provide IT and system administration services and undertake leadership reporting.

· External Third Parties including service providers who provide IT and system administration services, professional advisers who provide consultancy, banking, legal, insurance and accounting services and HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6 INTERNATIONAL TRANSFERS

We share your personal data within the Group. This will involve transferring your data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

· Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7 DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8 DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data: see   below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9 YOUR LEGAL RIGHTS

· Under certain circumstances, you have rights under data protection laws in relation to your personal data: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

· Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

· If you want us to establish the data’s accuracy.

· Where our use of the data is unlawful but you do not want us to erase it.

· Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

· You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

· Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10 GLOSSARY

LAWFUL BASIS

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

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How we use and protect your data

This Privacy Notice explains our approach on how we collect personal information about visitors of our website, how we use it, disclosure conditions to others and security provisions. References to “you” or “your” in this Privacy Policy means a visitor of our Website. Be informed that we will keep all of your personal information confidential, however we reserve the right to disclose this information in certain cases described herein. We confirm that we will keep the information on a secure server and that we fully comply with the applicable UK Data Protection regulatory framework at all times. We may change this Privacy Notice from time to time so please check this page occasionally so that you can see any changes. By using our website, you’re agreeing to be bound by this Privacy Notice. Any questions regarding this Privacy Notice and our privacy practices should be sent by email to our Data Controller (george.alexopoulos@exalens.com).  

Who are we?

Exalens is a registered trademark (UK00003516094) and trading name of Cyberlens Ltd, an Information Technology Limited Company, with a registered seat at 10-12 Mulberry Green, Old Harlow, Essex, CM17 0ET, United Kingdom. We specialize in the design of cybersecurity solutions and provision of relevant support services

How do we collect information from you?

We obtain information about you when you use our website, for example, when you contact us about services or products, or if you directly give us any information via forms.  

What type of information is collected from you?

We may collect and process one or more of the following categories of personal data about you or the company you represent:  

  • Information you provide to report a problem with the site.
  • Details of visits to our website and the pages and resources that are accessed, including but not limited to, traffic data, location data and other communication data that may assist us in understanding how visitors use the website. This may also include the resources that you access, and information about where you are on the internet including the domain type, IP address and URL that you came from. This information is collected and used for our internal research purposes and to improve our customer service.
  • The personal information we collect might include your name, address, email address, IP address, and information regarding what pages are accessed and when.
  • Information you provide to us by sending us a message through our website and information provided to us when you communicate with us electronically for any reason. If you contact us, we may keep a record of your email and other correspondence.
  • Information that you provide us as a result of filling in forms on our website, such as registering for information.

IP Addresses

We may collect information about your computer, including but not limited to, your IP address, operating system and browser type.  

How is your information used?

We may use your information:  

  • to ensure that the content on the site is presented in the most efficient way for you and the computer that you are using;
  • to enable you to participate in interactive features of the site;
  • to provide you with information relating to our website, product or our services that you request from us;
  • to provide you with information on other products that we feel may be of interest to you in line with those you have previously expressed an interest in via our website;
  • to meet our obligations arising from any contracts entered into by you and us;
  • to seek your views or comments on the services we provide;
  • to notify you about any changes to our website, including improvements, and service or product changes;
  • for our internal purposes including statistical or survey purposes, quality control, site performance and evaluation in order to improve our website;
  • to administer this website; and, if you consent, to notify you of products or special offers that may be of interest to you.

We review our retention periods for personal information on a regular basis. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.  

Who has access to your information?

We will not sell or rent your information to third parties. We will not share your information with third parties for marketing purposes but we may occasionally give a third party limited access to your contact information solely and specifically to obtain their assistance in organising marketing events or other promoting activities for our products (in which case they will be under strict GDPR compliant obligations on the security and use of your data). It should be noted that the subsidiary company(ies) of Exalens have also access to your information.

How Do I opt out?

You have a choice whether or not you wish to receive information from us. If you want to exercise this right and no longer be contacted by Exalens, then you can change your preferences by emailing the Data Controller (george.alexopoulos@exalens.com) and we will process your request within 7 working days.  

Your Rights

You have the following rights regarding your information:

  • To access personal data held about you
  • To request us to make any changes to your personal data if it is inaccurate or incomplete
  • To request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances
  • To object to, or restrict, our processing of your personal data in certain circumstances
  • If we use your personal data for marketing purposes, you can ask us to stop and we will comply with your request
  • If we use your personal data on the basis of having a legitimate interest, you can object to our use of it for those purposes, giving an explanation of your particular situation, and we will consider your objection
  • To object to, and not be subject to a decision which is based solely on, automated processing, which produces legal effects or could significantly affect you
  • To lodge a complaint with a data protection supervisory body, which is the Information Commissioner’s Office

To exercise any of your rights set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please email the Data Controller (george.alexopoulos@exalens.com).

Any complaints related to how we have handled your information should be sent to the attention of the Data Controller (george.alexopoulos@exalens.com).

Use of ‘cookies’

This website uses cookies to better the user’s experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device. Cookies are small files saved to the user’s computers hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website. Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors. This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computers hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information. Click here to read Google’s privacy notice for further information. Other cookies may be stored to your computers hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.  

Social Media Platforms

Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions, as well as the privacy policies, held with each social media platform respectively. Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email. This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.  

Shortened Links in Social Media

This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy urls. Users are advised to take caution and good judgement before clicking any shortened urls published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine urls are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.  

Links to other websites and partners

Our website and cyber services may contain links to other websites and services operated by our partners. This privacy policy applies only to Exalens‚ so we encourage you to read the privacy statements on the other websites/ partners you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. In addition, if you were referred to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third party site.  

Those aged 16 or Under

We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.  

Review of this Policy

We keep this Policy under regular review. This Privacy Notice was last updated in August 2021.

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