Privacy and Cookie Policies
Darwinium Privacy and Cookie Policies
We are committed to protecting your information and your right to privacy.If you have any questions or concerns about our Policy, or our practices with regards to your personal information, please contact us via [email protected].
When you use the Darwinium Services, you trust us with your information and we take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it.We hope you take some time to read through it carefully, as it is important.You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide the Darwinium Services to you and your use of the Darwinium Services. This Policy will not override any rights provided to you under the local privacy and data protection laws which apply in your jurisdiction.If there are any terms in this Policy that you do not agree with, please discontinue your use of the Darwinium Services.
Changes to this Policy or your personal information
We review this Policy regularly and it is your responsibility to check regularly and determine whether you still agree to comply with the Policy.If you do not agree to any changes to this Policy then you must immediately stop using the Darwinium Services.In the event we make any significant changes to this Policy we will use our reasonable endeavors to inform you of such changes in advance in writing.
It is important that the personal information we hold about you is true, complete, accurate and current.Accordingly, you must notify us of any changes to your personal information (for example, if you change your email address).
The Darwinium Services are owned and operated by Darwinium Pty Limited (ACN 648 622 851), a company registered in Australia and whose registered office is situated at 903/50 Clarence St, Sydney NSW 2000 Australia. Darwinium UK Limited (Company Number 13560780) and whose registered address is 49 Greek Street, London, England, W1D 4EG and Darwinium Holdings Inc [EIN 87-3979951] (together referred to as Darwinium/we/us/our).
Darwinium will either be a data controller or data processor of your personal information depending on the purposes for which it is collected and how it is used.For example when you are purchasing the Darwinium Services we will be collecting the personal information as data controller, however when you are using the Darwinium Services, in most circumstances, we will be acting as data processor as we will be carrying out services on your behalf.
As we have a number of different entities, the entity that is the data controller will vary depending on where you purchase the Darwinium Services from. If you are purchasing the Darwinium Services in Australia Darwinium Operations Pty Limited will be the data controller, if you are purchasing services in the UK, Darwinium UK Limited will be the data controller for your data, if you are purchasing the Darwinium Services in the USA Darwinium Inc. will be the data controller for your data and if you are purchasing the Darwinium Services outside of any of these countries then Darwium Operations Pty Ltd will be the data controller for your data.Darwinium Operations Pty Limited is the data controller in respect of this website.
It will depend on where you are based as to the data protection and privacy laws which shall apply to you, if you are unsure or have any questions on which data protection and privacy laws apply please contact us on [email protected].
The Darwinium Platform provides customer interaction, designed to delight not insult, detect not disable and automate not overload. It is security and protection at scale, with low-touch integration and immediate control. A decision platform that is future-proofed against new and evolving business challenges.
Information we may collect about you
Personal information you disclose to us
(a) Where and how we collect personal information
We collect personal information that you voluntarily provide to us when registering to use and actually using the Darwinium Services, or otherwise contacting us.
If you apply or are put forward for a role with us, or work for us (either directly or indirectly) for any period of time, we also collect your personal information, which may include your contact details, financial and payment details, details of your education, qualifications and skills, your marital status, your nationality, your NI number, your job title and your CV.
More particularly, the personal information that we collect depends on the context of your interactions with us, the choices you make and the products and features you use. For example:
- We gather information directly from you face to face if you come to our offices for information or to discuss an agreement and over the telephone if you ring us to make an enquiry.
- We collect personal information via our website, mobile applications and other technical systems.
- We collect personal information when you use our website or mobile applications to sign up to, participate in or receive a service from us, for example where you contact us, request information online, report an issue, provide feedback or enter a live chat.
- We may monitor and record communications with you (such as telephone conversations and emails). We may do this for a number of reasons, such as to check the quality of our customer service, for training purposes, to prevent fraud or to make sure we are complying with legal requirements.
- If you visit our offices, some personal information may also be collected from monitoring devices and systems such as closed-circuit TV (CCTV).
(b) The types of personal information we may collect
When you use the Darwinium Services and/or when you otherwise deal with us, we may collect the following information about you (the Information):
- Identity Data, which includes your first name, last name, gender and profile photo.
- Contact Data, which means the data we use to contact you including your billing address, delivery address, email address and contact number.
- Financial Data, if you receive any paid services, which means the payment method for example the card you use to pay for the Darwinium Services.
- Transaction Data, which means details about transactions you have made in connection with the Darwinium Services, including the payments to and from you along with other details of products you have purchased from us.
- Profile Data, which includes your username, email address and log-in data, details of any purchases or orders made by you, and your interests, preferences, feedback and survey or questionnaire responses.
- Usage Data, which includes Information about how you use the Darwinium Services.This includes your browsing patterns and Information such as how long you might spend on one of our webpages on the Darwinium Platform and what you look at and for, the page that referred you to the Darwinium Platform and the click stream during your visit to our website, page response times, and page interaction Information (for example, clicks you make on a page).
- Marketing and Communications Data, which includes your preferences with regards to receiving marketing from us and your other communication preferences.
- Information you upload that contains Information, content you provide through the Services, for instance projects, notes, tags, files or content, files, or other media that you import to the Services, through our integrations such as Google Drive, Zoom, or Zapier.
- Other Information relevant to services, customer surveys, questionnaires and/or offers.
Sensitive personal information
We will not usually ask you to provide sensitive personal information. We will only ask you to provide sensitive personal information if we need to for a specific reason, for example, if we believe you are having difficulty dealing with your account due to illness. If we request such information, unless otherwise permitted by law, we will explain why we are requesting it and how we will use it and obtain your explicit consent.
Sensitive personal information includes information relating to your racial or ethnic origin, political opinions, religious beliefs, whether you belong to a trade union or any other professional association or memberships, your physical or mental health or condition, biometric information, sexual orientation and practices, philosophical beliefs, and whether you have committed a criminal offence.
Personal information from third parties
Occasionally we may receive information about you from other sources, where permitted by law, we will add to the information we already hold about you in order to help us provide, improve and personalise the Darwinium Services. If you apply for a job with us, we may also receive information from those who provide references relating to your prospective or actual engagement or employment.
Information automatically collected
We automatically collect certain Information when you visit, use or navigate the Darwinium Platform.This Information does not reveal your specific identity (unless your device name is the same as your name) but may include device and usage Information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, Information about how and when you use the Darwinium Platform and other technical Information.This Information is primarily needed to maintain the security and operation of the Darwinium Platform, and for our internal analytics and reporting purposes.
How do we use your Information?
We use your Information collected via the Darwinium Services for a variety of business purposes described below.We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual Reasons), with your consent (Consent), and/or for compliance with our legal obligations (Legal Reasons).
We have set out below, in a table format, a description of the purposes which we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified examples of what our legitimate interests are where appropriate.
Note that we may process your personal information 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 information where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for process interest|
|To register you as a new customer to receive the Darwinium Services||(a) Identity Data, (b)Contact Data||Contractual Reasons|
|To process and deliver the Darwinium Services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us||(a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data (g) Marketing and Communications Data||(a) Contractual Reasons (b) Business Purposes for example to recover debts due to us|
|To facilitate a recruitment process in which you are involved||(a) Identity Data (b) Contact Data||(a) Business Purposes – for example to 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)||(a) Identity Data (b) Contact Data (f) Usage Data||(a) Legal Reasons for example 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) Legal Reasons|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity Data (b) Contact Data (e) Profile Data (f) Usage Data (g) Marketing and Communications Data||Business Purposes for example 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||(a) Technical Data (f) Usage Data||Business Purposes for example 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 or services that may be of interest to you||(a) Identity Data (b) Contact Data (f) Usage Data (e) Profile Data (g) Marketing and Communications Data||Business Purposes for example to develop our products/services and grow our business|
|To send you marketing and promotional communications||(a) Identity Data (b) Contact Data (g) Marketing and Communications Data||(a) Business Purposes for example to develop of products/services and grow our business (b) Consent|
|To enforce our terms and/or policies||(a) Identity Data (b) Contact Data||(a) Contractual Reasons (b) Business Purposes for example to protect our business|
|To respond to legal requests||(a) Identity Data (b) Contact Data||(a) Legal Reasons|
Will your Information be shared with anyone?
We only share and disclose your Information in the following situations:
- Contractual.We may share Information with any third parties we work with to enable any orders for services, or obligations arising out of any such orders, to be fulfilled.
- Compliance with Legal Obligations.We may disclose your Information where we are legally required to do so in order to comply with applicable laws, governmental requests, judicial proceedings, court orders, or legal processes, such as in response to a court order or a subpoena (including in response to requests from public authorities in order to meet national security or law enforcement requirements).
- Vital Interests.We may disclose your Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, illegal activities or situations involving potential threats to the safety of any person (including to contact emergency services, or to speak with your family, partner or support person where we reasonably believe there is a serious risk to the life, health or safety of you or another person and it is impracticable for us to obtain your Consent), or where we believe it is necessary for the purpose of providing evidence in connection with litigation proceedings in which we are involved.
- Third Party Service Providers.We may share your Information with third party vendors, service providers, credit reference agencies, trade associations of which we are a member, credit card associations, contractors or agents who perform services and require access to such Information to carry out that work, for example third party software developers).Such third parties will only have access to your Information to the extent that they need to perform those services.They are required to keep your Information confidential and may not use it other than as we ask them to and always in accordance with this Policy.
- Sharing with other users.Certain Information will be shared with other members of your workspace or people administering your workspace. These people are usually colleagues you work with day-to-day, or clients you have added to your workspace.
- Business Transfers.We may share or transfer your Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Business Partners.Provided you have given us Consent to do so we may share your Information with our business partners to offer you certain products, services or promotions.
- With your Consent.We may disclose your Information for any other purpose with your Consent, including with any person who you have named as a person we can contact to discuss your account and any agent or representative of yours.
- Internally. We may disclose your Information to our employees, contractors and/or related entities, for the purposes of providing our Services to you.
We may disclose aggregated, anonymous Information (i.e. Information from which you cannot be personally identified), or insights based on such anonymous Information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Darwinium Services.In such circumstances we will not disclose any Information which can identify you personally.
Is your Information transferred internationally?
Where we disclose your Information to third parties listed above, these third parties may store, transfer or access Information outside of the country in which you are based, including, but not limited to Australia, the United States and United Kingdom. Whenever we transfer your Information internationally, we will take all reasonably practicable measures to protect your Information in accordance with this Policy and applicable laws.To the extent that any transfer requires approved safeguards to be in place we will only transfer your Information to countries that have been deemed to provide an adequate level of protection for personal information or using any legally compliant methods for such transfer (including that where your personal information is solely subject to the Australian Privacy Act 1988 (Cth), that we may either seek your Consent to transfer your Information overseas or take such steps as are reasonable in the circumstances to require that overseas recipients protect your Information in accordance with the Australian Privacy Principles).
Automated decision making
Due to the nature of the fraud prevention services we provide, our use of your personal information may result in automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you.
Automated decisions mean that a decision concerning you is made automatically based on a computer determination (using software algorithms), without human review. For example, we use automated decisions to advise customers of potential fraud issues. We have implemented measures to safeguard the rights and interests of individuals whose personal information is subject to automated decision-making. You have the right to contest the decision if you are using the services in the EEA, please contract [email protected] for further information or to exercise this right.
Processing personal information of persons from the UK or European Economic Area (EEA)
If you are located in the UK or EEA, we process personal information in accordance with the principles of data processing under applicable laws, including the UK or EU general data protection regulation (GDPR). Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform our obligations under a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Third party websites
The Darwinium Platform may feature links to third party websites or social media channels, or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications.We cannot guarantee the safety and privacy of data you provide to any third parties.Any data collected by third parties is not covered by this Policy.
We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Darwinium Platform.You should review the policies of such third parties and contact them directly if you have any related questions.
For How long do we keep your Information?
We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax law, accounting requirements or other legal or regulatory requirements).
When we have no ongoing Business Purpose to justify the processing of your Information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.
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.
How do we keep your Information safe?
We have implemented appropriate technical and organisational security measures designed to protect the security of any Information we process.For example, we store your personal information on secure servers and company data is stored on separate secure encrypted disks when not in use.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.
However, please also remember that we cannot guarantee that the Internet itself is 100% secure.Although we will use our reasonable endeavours to protect your Information, we cannot guarantee the security or integrity of personal Information that is transferred from you or to you via the Internet. Transmission of personal Information to and from the Darwinium Platform is therefore at your own risk.You should only access our services within a secure environment.
Do we collect Information from minors?
We do not knowingly solicit data from or market to children under 16 years of age.By using the Darwinium Services, you represent that you are at least 16 years of age.If we learn that Information from users less than 16 years of age has been collected, we will deactivate the relevant account and take reasonable measures to promptly delete such data from our records.If you become aware of any data we have collected from children under 16 years of age, please contact us immediately via [email protected].
Your Consent to processing
You will be required to give Consent to certain processing activities before we can process your Information.Where applicable, we will seek Consent from you when you first submit Information to or through the Darwinium Services.
If you have previously given your Consent you may freely withdraw such Consent at any time.You can do this by emailing [email protected], where applicable, clicking the ‘Unsubscribe’ button that appears in mailing list communications.
If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information.If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.
Please note that if we need to process your Information in order for you to use the Darwinium Services and you object or do not provide Consent to us processing your Information, you accept that the Darwinium Services will no longer be available to you.
Marketing and opting out
If you have given Consent to marketing (or we are otherwise permitted to send you marketing materials under applicable law) we may contact you about our products, services, promotions and special offers.If you no longer wish to receive such Information, you can withdraw your Consent or otherwise opt-out of receiving marketing materials at any time by sending an email to [email protected] or unsubscribe using the opt-out facilities provided in the communications.
If you have given Consent, we may share your Information with carefully selected third party organisations and business partners and they may contact you directly.If you would prefer to no longer receive direct marketing communications from third parties and partners after previously giving your Consent, please contact those third parties and partners directly to withdraw the Consent.
You may at any time review or change the Information in your account by logging into your Darwinium account.
If you wish to terminate your Darwinium account, please contact us via [email protected] and we can arrange this for you.Some Information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our terms and conditions and/or comply with legal requirements.
What are your privacy rights?
You have certain rights in relation to the Information that we hold about you depending on where you are located or from.For EU and UK citizens and residents you have a number of specific rights, details of these rights and how to exercise them are set out below.If you are based in another country and request to exercise one of the rights below or any other right you may have, we will do our best to fulfil such a request and will always fulfil the request if legally required.Please note that we will require evidence of your identity before we are able to respond to any requests.This is a security measure to ensure that your Information is not disclosed to a person who does not have the 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.To exercise or discuss any of your rights, please contact us via [email protected].
UK and EU Citizens
- Right of Access.You have the right at any time to ask us for a copy of the Information that we hold about you and to check that we are lawfully processing it.Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your Information, or certain elements of the request.If we refuse your request or any element of it, we will provide you with our reason(s) for doing so.
- Right of Correction or Completion.If Information we hold about you is not accurate or is out of date and requires amendment or correction, you have a right to have the data rectified or completed.
- Right of Erasure.In certain circumstances, you have the right to request that the Information we hold about you is erased (for example, if the Information is no longer necessary for the purposes for which it was collected or processed or our processing of the Information is based only on your Consent and there are no other legal grounds on which we may process the Information).
- Right to Object to or Restrict Processing.In certain circumstances, you have the right to object to our processing of your Information (for example, if we are processing your Information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests).
You may also have the right to restrict our use of your Information, for example during a period in which we are verifying the accuracy of your Information in circumstances where you have challenged the accuracy of that Information.
- Right of Data Portability.In certain instances, you have a right to receive the Information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format.
In such circumstances, you can ask us to transmit your Information to you or directly to a third-party organisation on your behalf.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems.We are also unable to comply with requests that relate to personal Information of others without their consent.
If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time.Please note however that this will not affect the lawfulness of the processing that occurred before the withdrawal of such Consent.
Where your Information is subject to the Australian Privacy Act 1988 (Cth), you also have a number of specific rights, details of these rights are set out below.
- Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such personal information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your Information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your personal information in another form that still meets your needs, then we will take reasonable steps to give you such access.
- Correction: If you believe that any personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your Information. If we cannot correct your personal information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
- Anonymity: Where practicable, we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
If you are a California resident you may have certain rights under the California Consumer Privacy Act (CCPA) regarding your personal information, including:
- the right to request the specific pieces of personal information we collected about you; the categories of personal information we collected; the categories of sources used to collect the personal information; the business or commercial purposes for collecting your personal information; and the categories of third parties with whom we share your personal information each as it pertains to our activities in the preceding twelve (12) months
- the right to request, on legitimate grounds, deletion of your personal information that we collected;
- the right to have someone you authorize make a request on your behalf; and
- the right, in certain circumstances, to correct inaccurate personal information we collected about you; and
- the right not to be discriminated against for exercising any of these rights.
We also must provide in this online disclosure certain details about our collection and handling of categories of personal information – this is set out at the start of the Policy.
If you have any questions or requests related to your rights under the CCPA or wish to exercise any of your CCPA rights please contact us on [email protected].
Sale of Personal Information
Darwinium does not offer an opt-out from the sale of personal information because Darwinium does not engage in the sale of personal information as contemplated by the CCPA.We may personal information to other businesses for a variety of reasons, however we do not disclose personal information for the sole purpose of receiving compensation for that information.
We welcome your feedback and questions on this Policy and any complaints you may have regarding this Policy or the Darwinium Services.If you wish to contact us about this Policy, any complaints or have any other questions, please email us via [email protected] you are contacting us regarding a complaint please provide us with full details of the complaint.We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and any potential steps we will take.
You have the right to make a complaint at any time to the relevant supervisory body, for example:
In the UK the Information Commissioner’s Office (the ICO) (https://ico.org.uk/concerns)
In Australia, the Office of the AustralianInformation Commissioner https://www.oaic.gov.au/privacy/privacy-complaints
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you consent.Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
- Strictly necessary cookies.These cookies are required for the operation of the Darwinium Platform.They include, for example, cookies that enable you to log in to secure areas of the Darwinium Platform, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies.These cookies allow us to recognise, and count the number of, visitors and to see how visitors move around the Darwinium Platform when they are using it.This helps us to improve the way the Darwinium Platform works, for example by ensuring that users are finding what they are looking for easily.
- Functionality cookies.These cookies enable us to recognise you when you return to the Darwinium Platform.This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies.These cookies record your visit to the Darwinium Platform, the pages you have visited and the links you have followed.We will use this information to make the Darwinium Platform and the advertising displayed on it more relevant to your interests.We may also share this information with third parties for related purposes.
You can find more information about the individual cookies we use and the purposes for which we use them in the below table:
|Cookie Type||Cookie Name||Purpose||More Information|
|Analytical/ performance cookies||Google Analytics||This cookie helps us to: (a) Estimate our audience size and usage pattern. (b) Understand how visitors navigate to and through the Darwinium Platform. (c) Track the effectiveness of digital marketing campaigns. (d) Recognise you when you return to the Darwinium Platform.||You can find out more about Google Analytics here.|
|Targeting Cookies||Google Tag Manager||This cookie helps us to understand visitor information and the source of visits.||You can find out more about Google Tag Manager here.|
The most popular web browsers all allow you to manage cookies.You can choose to accept or reject all cookies, or just specific types of cookies.
How to manage cookies in different web browsers
Most browsers will allow you to turn off cookies, although please note that turning off cookies may restrict your use of the Darwinium Platform.
The following links provide information on how to modify the cookies settings on some popular browsers:
Please note that we do not currently respond to Do Not Track (DNT) signals.
We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Darwinium Platform, but this remains your personal choice.
You can also visit the About Cookies website, for more information about cookies and how to manage them.
Third Party Cookies
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Darwinium Platform.
If you would like more information about these third-party cookies, it is available from www.youronlinechoices.com/uk.
Note that when third parties are collecting information about you, those third parties are acting as controllers in their own right (i.e. they are not acting on our behalf).
We will review, and where necessary update, this policy.If we have your e-mail address, we may notify you of any updates and, if necessary, ask you to confirm that you consent to such updates.