Privacy Policy - United States

Privacy Policy for North American Tickets White Label Site

Last Updated: May 3, 2024

North American Tickets, LLC (the “Company”) and “Encore Tickets, Ltd. (" Encore ") are committed to protecting your privacy. Encore is a Limited company organized under the laws of England and Wales. We have prepared this Privacy Policy to describe our practices regarding the Personal Data (as defined below) we collect from your interactions with us (all of which are collectively referred to herein as our " Services ").” Our Terms & Conditions, which can be found in the footer section of this website, also cover your use of our Sites and Services; so please make sure you read our Terms & Conditions carefully.

This Site is branded as the E-Commerce Partner’s but is maintained by Encore and when you purchase a ticket, Encore will be the primary provider of the Services. When we talk about the "E-Commerce Partner" in this policy, we are referring to our commercial partner Hollywood.com which jointly provides the web services on this website (the "Site"). Company, Encore, and our E-Commerce Partner are each considered a data "Controller" for the purposes of the General Data Protection Regulation (GDPR), and other data protection laws applicable in the United Kingdom and Member States of the European Union.

You also have a right to contact Encore in regard to exercising your data rights, the details of which are included below.

If you are a user outside of the United States, you may also contact us at: Encore Tickets, 5 New Street Square, London, EC4A 3TW United Kingdom; Email: support@tixculture.com.

1. Questions; Contacting Us; Reporting Violations. If you have any questions, concerns, or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations, please contact us as follows: North American Tickets, LLC., 1501 Broadway, Suite 1313, New York, NY 10036.

2. User Consent. By using our Services, you agree to the terms of this Privacy Policy and our Terms of Use, and you expressly consent to the collection, use, and disclosure of your Personal Data in accordance with this Privacy Policy and our Terms of Use. If you do not agree with these terms, please do not use our Services.

3. A Note to Users Outside of the United States. If you are using our Services from outside of the United States, by using the Services and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding the processing of Personal Data may be different than the laws in your country. By providing your Personal Data, you consent to such transfer.

4. Types of Data We Collect. " Personal Data " means data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. " Deidentified Data " means data that cannot reasonably identify, relate to, describe, be capable of being associated with or be linked, directly or indirectly, to a particular consumer. Deidentified Data does not, by itself, permit the identification of individual persons. We collect the following Personal Data and Deidentified Data, as described and in the manners identified below.

4.1 Personal Data Categories. The following are the types of Personal Data that we collect and do not collect.

Personal Data Collected. 

• Identifiers such as a real name, alias, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

• Commercial information, including records of products or services purchased, obtained, considered, or other purchasing or consuming histories or tendencies as provided through your use of our Services.

• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our Services, or advertisement, only to the extent you provide such information in connection with our provision of services.

Personal Data Not Collected.

• Bank account number, credit card number, debit card number, or any other financial information,

• Audio, electronic, visual, thermal, olfactory, or similar information.

• Education information, as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).

• Inferences drawn from any of the information identified in this Section 4.1 to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

• Sensitive Personal Information, including biometric information, precise geolocation data, characteristics of protected classifications under California or federal law, social security, driver’s license, state identification card, or passport numbers, and the contents of your messages, email and text messages unless we are the intended recipient of the communication.

Collection of Invitee/Guest Personal Data.

• When purchasing tickets, you may have the option to provide the name and email address of invitees or guests who will receive tickets and show information directly. We will only use this information for the specified purpose and in accordance with this Privacy Policy.

4.2. Information You Provide to Us.

We may collect Personal Data from you, such as your first and last name, email address, and password when you create an account to log in to our network (" Account ").

• If you use our Services on your mobile device we may collect your phone number and the unique device id number.

• If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can disable on your mobile device the ability of our Services to receive location-based information.

• Certain Services may require our collection of your phone number. We may associate that phone number with your mobile device identification information.

• When you order products or services through our Services, we will collect all information necessary to complete the transaction, including your name,  billing information and shipping information. We may also collect your contractual details, such as your purchase and order record, including booking details for shows purchased, ticket quantities, and cost.

• If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.

• If you participate in a sweepstakes, contest, lottery, or giveaway offered via our Services, we may ask you for your first and last name, postal address, email address, and/or telephone number (e.g., to notify you if you’ve won or to comply with relevant law). In some situations, we may need additional information as a part of the entry process. These sweepstakes and contests are voluntary. You should read the rules for each sweepstakes and contest that you enter.

• We may also collect Personal Data at other points within our Services that state that Personal Data is being collected.

4.3. Information You Provide to Facebook and other Social Networking Sites (SNS). The Services may allow users to access Facebook (or another SNS) to interact with friends. If you are already logged into the Services and Facebook (or another SNS), when you click on "Connect with Facebook," or a similar function for another SNS, you will be prompted to merge your profiles. If you are already logged into the Services but not logged into Facebook or another SNS that we support, when you click on "Connect with Facebook," or a similar function for another SNS, you will be prompted to enter your SNS credentials or to "Sign Up" for the SNS. By proceeding, you are allowing the Services to access your information and you are agreeing to Facebook’s or other SNS’s Terms of Use in your use of the Services. Conversely, if you are not currently registered as a user of the Services, and you click on "Sign in" using Facebook or another SNS that we support, you will first be asked to enter your Facebook or SNS credentials and then be given the option to register for the Services. In this case, we may receive information from Facebook or another SNS to make it easier for you to create an Account with us and show our relevant content to your Facebook or SNS friends. Once you register with us and connect with Facebook or another SNS, you will be able to automatically post recent activity back to Facebook or the other SNS. Any information that we collect from your Facebook or other SNS account may depend on the privacy settings you have established with that SNS, so please consult the SNS’s privacy and data practices. You have the option to disable your connection with Facebook or another SNS at any time by logging into your account with us and modifying your settings accordingly.

4.4. Information Collected via Technology.

• Information Collected by Our Servers. To make our Services more useful to you, our servers (which may be operated by a third party, including Amazon Web Services) collect information from you, including information about the device you use to access our Services, the date and time you access our services, etc.

• Log Files. Like many online services, we gather certain information automatically and store it in log files. When using our Services, this information generally includes IP addresses, browser type, Internet service provider (" ISP "), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer our Services, track users’ movements within our Services, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. We do not link this automatically-collected data to Personal Data.

• Cookies. Like many online services, we use cookies to collect information. " Cookies " are small pieces of code that a website or app sends to your device. For users of our Services, we may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience.

• Mobile Services. We may also collect De-identified Data from your mobile device if you have downloaded our mobile application. Examples of information that may be collected and used include your geographic location, how you use the application, and information about the type of device you use (such as manufacturer and model of your device, your preferred language, unique device identifier, IP address of the device, and your location). In addition, in the event our Services crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Services. This Deidentified Data is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.

4.5. Information Collected from You About Others. If you decide to invite a third party to create an account with us, we will collect your and the third party’s names and email addresses or phone numbers in order to follow up with the third party. We rely on you to obtain whatever consents from the third party are required by law to allow us to access and collect the third party’s name and email address as required above. You or the third party may request that we delete this information as described in Section 10.3 of this Privacy Policy. When you invite friends to the Services, we will access your address book and we will import your contacts’ names and email addresses or phone numbers in order to facilitate the invitation. The email that is sent to your friends will come from your email address so that your friends know that you want to invite them to access our Services. We do not store any passwords you provide as part of the contact import process. We also collect some settings that help us to interpret your data, such as the language and keyboard settings that you have established, and the phone’s carrier, mobile network code, and mobile country code.

4.6. Location Information. If you have enabled location services on your phone with respect to our Services, we collect your location information to suggest products or services in your general area. If you do not want this information collected by us, you can disable location services on your phone with respect to our Services.

4.7. A Note About Children. We do not knowingly gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to us and we learn that the Personal Data relates to a child under 13, we will attempt to delete the information as soon as possible. In addition, we do not sell or share Personal Data related to a child under 16. If you believe that we might have collected any Personal Data from a child under 13, please contact us at support@tixculture.com.

5. Use of Your Personal Data.

5.1. General Use. In general, Personal Data you submit to us is used either to respond to requests that you make or to aid us in serving you better. We use your Personal Data in the following ways:

• To facilitate the creation of and to assist our efforts to secure your account;

• To identify you as a user in our system;

• To provide improved administration of our Services;

• To provide the Services you request;

• To improve the quality of experience when you interact with our Services;

• To send you a welcome email to verify ownership of the email address provided when your account was created;

• To send you administrative email notifications, such as security or support and maintenance advisories; and

• To send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes.

5.2. Creation of Deidentified Data. We may create De-identified Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Deidentified Data to analyze request and usage patterns so that we may enhance the content and navigation of our Services. We reserve the right to use Deidentified Data for any other purpose and disclose Deidentified Data to third parties in our sole discretion.

6. Short Message Services and WAP. We may make available services through which you can receive messages on your phone or wireless device. We may also make available content via WAP and mobile services. If you subscribe to one of our SMS services or an SMS service of one of our partners, you thereby agree to receive services and messages at the address you provide for such purposes. We will use the information we obtain in connection with these services in accordance with this Privacy Policy and the Terms of Use. Your wireless carrier and other service providers may also collect data about your wireless device usage, and their practices are governed by their own policies. By signing up for any SMS service, you consent to receive messages as described above and in our Terms of Use. You understand that your wireless carrier’s standard rates apply to these messages. You represent that you are the owner or authorized user of the wireless device on which messages will be received and that you are authorized to approve the applicable charges.

7. Disclosure of Your Personal Data. We disclose your Personal Data as described below. We share your Personal Data with your consent or to complete any transaction or provide any product or service you have requested or authorized. We also share Personal Data with our Affiliates; with vendors working on our behalf; when required by law or to respond to legal process; to protect our customers; to maintain the security of our products and services; and to protect the rights and property of the Company and its customers.

7.1. Third Parties Designated by You. When you use the Services, the Personal Data you provide will be shared with the third parties that you designate to receive such information, including other websites, your friends, relatives, and business associates. Depending on the type of access you grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information. You may change your settings at any time as to who has access to your information by going to your account settings and changing your publishing options.

7.2. Third-Party Service Providers. We may share your Personal Data with third-party service providers to: provide you with the products or services that we offer you or that you order through our Services; to conduct quality assurance testing; to facilitate the creation of accounts; to provide technical support; and/or to provide other services for us. We require these third-party service providers to not use, retain or share your Personal Data other than to provide services for us.

7.3. Theatre Partners, Agents, Contractors. We may disclose your Personal Data to any of our theatre partners, or to our agents or contractors who assist us in providing our services and products, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analyzing data, providing support services or in other tasks, from time to time. Our theatre partners, agents, and contractors will only use your information to the extent necessary to perform their functions.

7.4. Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under common control with us (" Affiliates "), in which case our Affiliates will honor this Privacy Policy.

7.5. Corporate Restructuring. We may share some or all of your Personal Data in connection with or during the negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires us, our business, or some or all of our assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

7.6. Social Networking Sites. Some of our Services may enable you to post content to SNSs. If you choose to post content to an SNS, we will provide information to the applicable SNS in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of any SNSs and that it is your responsibility to review the terms of use and privacy policy of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.

7.7. Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), we may disclose Personal Data if we believe in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or legal obligations, or to respond to subpoenas or warrants served on us; (iii) to protect or defend our rights or property or users of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

8. Third-Party Services. Our Services may contain links to services provided by third-party companies (" Third-Party Companies "). When you click on a link to any other website or location, you will leave our Service and go to another service, and another entity may collect Personal Data or Deidentified Data from you. We have no control over, do not review, and cannot be responsible for, these Third-Party Companies or their content. Please be aware that the terms of this Privacy Policy do not apply to any Third-Party Companies or content, or to any collection of your Personal Data after you click on links to such Third-Party Companies. We encourage you to read the privacy policies of every service you use. The links to Third-Party Companies are for your convenience and do not signify our endorsement of such Third-Party Companies or their content, products, or services.

9. Your Choices Regarding Information. You have several choices regarding the use of information on our Service:

9.1. Email Communications. We will periodically send you free newsletters and emails that directly promote the use of our Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt out" by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information in Section 10.2 below). Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our Terms of Use or Privacy Policy.

9.2. Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the services you access. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or obtain the benefit of the complete functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.

9.3. De-Linking SNS. If you decide at any time that you no longer wish to have your SNS account linked to your account with us, then you may de-link the SNS account in the "preferences" section in your account settings. You may also manage the sharing of certain Personal Data with us when you connect with us through an SNS. Please refer to the privacy settings of the SNS to determine how you may adjust such permissions and manage the interactivity between the Services and your social media account. 

9.4. How We Respond to Do Not Track Requests. The major browsers have attempted to implement the draft “Do Not Track” ("DNT") standard of the World Wide Web Consortium ("W3C") in their latest releases. As this standard has not been finalized, our Services are not compatible with DNT. We do not recognize DNT instructions or any other automated browser signals regarding tracking mechanisms. For information on all of these categories of cookies, and for more information generally on cookies please refer to aboutcookies.org.

9.5. Changing or Deleting Your Personal Data. You may change any of your Personal Data in your account by editing your profile. Pursuant to Section 10 below, you may request deletion by us of your Personal Data, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database but may remain in our archives. We may also retain your information for fraud detection or similar purposes.

9.6. Applications. You can stop all collection of information by our mobile application(s) by uninstalling and deleting the application(s). You may use the standard uninstall processes available on your mobile device or via the mobile application marketplace or network.

10. Notice to California Residents. The California Consumer Protection Act (CCPA) and the California Privacy Rights Act of 2020 (CPRA) provide consumers (California residents) with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how you exercise those rights.

10.1. Your Rights.

What Personal Data We Collect

You have the right to know what kinds of Personal Data we collect and our business purposes for that collection. We make this information available to consumers in the “Types of Data We Collect” section of this Privacy Policy.

How We Use Your Personal Data

You have the right to know how Personal Data is obtained, how it is used, and our business purposes for that use.

We make this information available to consumers in the “Use of Your Personal Data” section of this Privacy Policy.

How We Share Your Personal Data

You have the right to know if your Personal Data is shared with any third parties. We may share Personal Data to have Service Providers, as defined by the CCPA, perform services specified by written contract. In addition, we may share Personal Data with third parties for other permitted purposes, as permitted by the CCPA.

We make this information available to consumers in the “Disclosure of Your Personal Data” section of this Privacy Policy.

Right to Opt-Out of Sharing of Personal Data

We may “share” Personal Data with third parties for personalized advertising purposes. Consumers may indicate their choice to opt out of the sharing of Personal Data with third parties for personalized advertising on third-party sites by clicking here.

We Do Not Sell Your Personal Data

You have the right to know whether your Personal Data is being sold. Your Personal Data is sold when it is shared with or communicated to a third party for monetary or other valuable consideration except (i) if you interact with one or more third parties, or direct us to do so, (ii) for purposes of conveying opt out requests or (iii) in connection with a transaction in which such third party assumes control of all or part of our business.

We do not sell your Personal Data, so we do not offer an opt-out.

Right to Know, Right to Receive, Right to Correct, Right to Delete, Right to Opt-Out

You have the right to:

• Know what specific pieces of Personal Data the Company has collected and retained about you over the previous 12 months.

• Receive a copy of your Personal Data.

• Correct your Personal Data that the Company may have collected.

• Delete your Personal Data.

• Right to Opt-Out of sharing or selling your Personal Data.

10.2. Access Request; Information About Data Collected and Shared; Correct Personal Data. You have a right to request that we disclose certain information to you about our collection and use of your Personal Data. You can make an access request by clicking here or mailing your request to: North American Tickets, LLC, 1501 Broadway, Suite 1313, New York, NY 10036, Attn: Data Privacy. We will provide you the following information within 45 days of our receipt of a verifiable consumer request from you:

• The categories of Personal Data we collect about you.

• The categories of sources from which the Personal Data is collected.

• The business or commercial purpose for collection of your Personal Data.

• The business or commercial purpose for the sharing of your Personal Data.

• The categories of persons with whom we share your Personal Data.

• The specific pieces of Personal Data we have collected about you.

You also have the right to request that the Company correct certain Personal Data that we may have collected about you. To do so, please make a correction request by emailing support@tixculture.com or mailing your request to: North American Tickets, LLC, 1501 Broadway, Suite 1313, New York, NY 10036, Attn: Data Privacy.

We will respond to your right to access, right to know and right to correct requests within 45 days, unless additional time (up to 45 more days) is needed, in which case we will let you know.

10.3. Deletion Request: Requesting Deletion of Personal Data. You may choose to request the deletion of Personal Data collected by the Company. Within 45 days of our receipt of a verifiable consumer request from you, we will delete the Personal Data we have collected about you, except for situations when that information is necessary for us to: provide you with a good or service that you requested; perform a contract the Company entered into with you; maintain the functionality or security of our systems; comply with or exercise rights provided by applicable law; or use the information internally in ways that are compatible with the context in which you provided the information to us or that are reasonably aligned with your expectations based on your relationship with the Company. To exercise your right to request the deletion of your Personal Data, either email support@tixculture.com or mail your request to: North American Tickets, LLC, 1501 Broadway, Suite 1313, New York, NY 10036, Attn: Data Privacy. Requests for the deletion of Personal Data are free.

We will respond to your deletion requests within 45 days unless additional time (up to 45 more days) is needed, in which case we will let you know.

10.4. Opt-Out of Sale of Personal Data. We do not sell your Personal Data to any third party.

10.5. Targeted Advertising; Opt-Out.  We may use your Personal Data for certain targeted advertising purposes. You can opt out of our sharing of Personal Data to Third-Party Companies by either clicking here or mailing your request to: North American Tickets, LLC, 1501 Broadway, Suite 1313, New York, NY 10036, Attn: Data Privacy.

10.6.  Sensitive Personal Information.  We do not collect, use or disclose your Sensitive Personal Information (as defined in the CCPA) for any purposes.

10.7. Process to Verify Consumer Requests. When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the Personal Data we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you are a registered customer, we may ask you to sign in to your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your Personal Data, we will only complete your request when we are satisfied that we have verified your identity to a reasonable degree of certainty.

If you have a Norther American Tickets, LLC account. To access or delete Personal Data related to a North American Tickets, LLC account, users can log in to their account and make a request directly to our privacy team. It is important to note that a valid login is required to access or delete Personal Data associated with a North American Tickets, LLC account. This safeguard is in place to protect the security of consumers and their data.

If you do not have a North American Tickets, LLC account. If you do not have a North American Tickets, LLC account or would like to export or delete Personal Data not linked to a North American Tickets, LLC account, you can make a request directly to our privacy team at support@tixculture.com. As this request is for Personal Data outside of a logged-in North American Tickets, LLC account experience, we require two identification factors, such as a verified email and phone number, to process a request to access Personal Data.

10.8.  Authorized Agents. The CCPA allows California consumers to designate an authorized agent to exercise certain of their rights under the CCPA.  To exercise your rights on your behalf, your authorized agent may follow the same steps outlined in this Privacy Policy.  Authorized agents will be required to provide proof of their authorization, in particular written permission signed by the consumer, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.  We will not charge the authorized agent a fee in connection with their request.

10.9.  Opt-Out Preference Signals. In addition to the advertising opt-out options above, we capture opt-out preference signals, and to the extent users have rights under applicable law, treat them as valid requests to opt out of sale/sharing at the browser level. An opt-out preference signal is a setting or extension in a browser or device that a web user sets to prevent the selling or sharing of personal information on sites the browser or device visits. We will process your signal as a request to opt information associated with your device, browser, and/or consumer profile out of selling and sharing with third parties.

11. Security of Your Personal Data.

• For online payments, we use the payment services of Adyen. We do not process, record or maintain your credit card or bank account information.

• We are committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your account. Please do not disclose your account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we use reasonable efforts to protect your Personal Data, we cannot and do not guarantee its absolute security.

12. Non-Discrimination. Providing your Personal Data may be a requirement necessary to enter into or to perform a contract, including for the performance of the Services, and replying to and managing requests for information, questions, communication, or feedback. In such circumstances, refusal to provide your Personal Data would make it impossible for us to perform the contract or to provide the requested Services. However, providing your Personal Data for marketing purposes alone is optional; refusal to provide your Personal Data for marketing purposes will not have any impact on the performance of our Services.

13. Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and we will change the "Last Updated" date above. You should consult this Privacy Policy regularly for any changes.