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Privacy Policy

Lay Beach Club

1. Identification

  • Holder: Aquatique Pattaya Co., Ltd.
  • TAX ID No.: 0105561012371
  • Registered office: LAY Beach Club, 429/8 Moo 9, Nongprue, Banglamung, Pattaya, Thailand, Chon Buri
  • Registry data: LAY Beach Club, 429/8 Moo 9, Nongprue, Banglamung, Pattaya, Thailand, Chon Buri
  • Email: Info@laybeachclub.com
  • Data Protection Officer (DPO): The User may contact the DPO through the following email address: Info@laybeachclub.com, or by writing to the address of LBC marked for the attention of the “Data Protection Officer”.
  •  

2. Information and Consent

By reading this Privacy Policy, the user is hereby informed on how LBC collects, processes and protects personal data furnished through the website www.laybeachclub.com (hereinafter, the “website”), as well as through their connection and browsing of the Website (hereinafter, “browsing”) and those other data that may be provided in the future to LBC through the Accommodation Agreement or any other enabled means.

The User must carefully read this Privacy Policy, which has been written clearly and simply, to facilitate its understanding, and to freely and voluntarily determine whether he/she wishes to provide their personal data, or those of third parties, to LBC.

3. Obligatory Nature of Providing the Data

The data requested in the forms accessible from the LBC Website are, in general, mandatory (unless specified otherwise in the required field) to meet the stated purposes. Accordingly, if they are not provided or are not provided correctly, we will be unable to process the request.

4. For what Purpose will LBC Process the User’s Personal Data and for How Long?

Depending on the User’s requests, the personal data collected will be processed by LBC in accordance with the following purposes:

  • To manage the bookings made, including payment management (where applicable) and the management of the user’s requests and preferences.
  • To manage the subscription to the newsletter and subsequent sending of this.
  • To manage registration in the Membership programme, as well as obtaining and redeeming points.
  • To manage the User’s contact requests with LBC through the channels provided to this end.
  • To manage the sending of personalised commercial communications of the LBC, by electronic and/or conventional means, in cases in which the User expressly consents.
  • To manage the sending of personalised commercial communications of the Membership programme, unless the User specifies otherwise by marking the corresponding box, or opposes said processing.
  • To manage the provision of the contracted restaurant service, as well as additional services.
  • To manage surveys and/or evaluations regarding the quality of the services provided by LBC and/or the perception of its image as a company.


The User’s data will be kept for the period required to fulfil each purpose or until the User requests their withdrawal from LBC, opposes or revokes their consent.

5. What User Data will LBC Process?

LBC may process the following categories of data, depending on the request made by the User:

  • Identification data: name, surname(s)
  • Contact details: Postal address, mobile telephone number, email address.
  • Data corresponding to the Membership loyalty programme.
  • User ID codes or passwords.
  • Personal data: date of birth, gender, nationality.
  • Details of preferences.
  • Geolocation data.
  • Card data, required for payment of the booking or to guarantee the same as well as to pay for the stay or the services associated with it.


In the event of registration and/or access through a third-party account, LBC may collect and access certain information of the User’s profile from the corresponding social network, solely for internal administrative purposes and/or for the purposes indicated above.

In the event that the User provides third-party data, he/she declares that they have the third party’s consent and undertakes to provide the interested party -the data holder- with the information contained in this Privacy Policy, duly exonerating LBC from any liability in this regard. However, LBC may carry out the necessary verifications to verify this fact, adopting the corresponding due diligence measures, in accordance with the data protection regulations.

6. What is the Legitimation for the Processing of your Data?

The data processing required in fulfilment of the aforementioned purposes that require the User’s consent cannot be undertaken without said consent.

Likewise, in the event that the User withdraws their consent to any of the processing, this will not affect the legality of the processing carried out previously.

To revoke such consent, the User may contact LBC through the following channels: By means of a letter addressed to Lay Beach Club 429/8 Moo 9, Nong Prue, Bang Lamung, Chonburi 20150 Thailand, or by means of an email sent to Info@laybeachclub.com, in both cases with the Reference “Data Protection”.

By the same token, in those cases in which it is necessary to process the User’s data for the fulfilment of a legal obligation or for the execution of the existing contractual relationship between LBC and the User, the processing would be legitimized as it is necessary for compliance with said purposes. Elsewhere, the processing undertaken in the performance of surveys and/or evaluations regarding the quality of the services provided by LBC and/or the perception of its image as a company will be carried out on the basis of the legitimate interest of the data controller.

7. To which Recipients will the User’s Data be Disclosed?

The User’s data may be disclosed to:

  • Investee companies or companies of the LBC, solely for internal administrative purposes and/or for the purposes indicated above.
  • Operators of hotels managed by LBC or under a franchise agreement, solely for internal administrative purposes and/or for the purposes indicated above.
  • Suppliers of LBC or of the hotel operators necessary for the adequate fulfilment of the legal obligations and/or the purposes previously indicated.
  • Partners and collaborating companies of the LBC for the fulfilment of the aforementioned purposes and/or, if so authorised, for sending commercial communications.
  • Public Administrations, in the cases provided for under Law.


The recipients indicated in this section may be located within or outside the European Economic Area, in the latter case international data transfers must be duly legitimized.

8. User’s Responsibility

The User:

  • Guarantees that they are of legal age or legally emancipated, where applicable, fully capable, and that the information given to LBC is true, accurate, complete and up-to-date. For these purposes, the User is responsible for the truthfulness of all the data communicated and will keep the information updated, so that said data reflects their actual situation.
  • Guarantees that he/she has informed third parties on whose behalf he/she has provided data, where applicable, of the aspects contained in this document. Also guarantees that he/she has obtained the third party’s authorisation to provide their data to LBC for the purposes indicated.
  • Will be responsible for false or inaccurate information provided through the Website and for damages, whether direct or indirect, that this may cause to LBC or third parties.


9. Comercial and Promotional Communications

One of the purposes for which LBC processes the User’s data will be for the sending of commercial communications, through electronic and/or conventional means, with information concerning products, services, promotions, offers, events or relevant news for Users. Whenever any communication of this type is made, it will be sent solely and exclusively to those Users who have authorised its reception and/or who have not previously expressed their refusal to receive them.

To carry out the foregoing task, LBC may analyse the data obtained in order to create user profiles that allow a more detailed definition of the products that may be of interest.

In the event that the User wishes to stop receiving commercial or promotional communications from LBC, he/she may request cancellation of the service by sending an email to the following email address: Info@laybeachclub.com, as well as indicating their wish not to receive them through the withdrawal option provided in each of the commercial communications sent.

10. Geolocation Data

Some of the LBC App functionalities allow geolocation of the device (Tablet, Smartphone, etc.) on which it is installed.

The User may disable this option directly on the device itself; however, disabling this option may prevent the use of some of the App features.

11. Exercise of Rights

The User may send a letter to Lay Beach Club 429/8 Moo 9, Nong Prue, Bang Lamung, Chonburi 20150 Thailand, or through an email to the address Info@laybeachclub.com, in both cases with the Reference “Data Protection”, and attaching a photocopy of the current ID document or passport, at any time free of charge, to:

  • Revocation of consent granted.
  • To obtain confirmation about whether or not personal data concerning the User is being processed at LBC.
  • Oppose the treatment.
  • To access their personal details.
  • To rectify any inaccurate or incomplete data.
  • To request the deletion of their personal data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
  • To obtain from LBC the limitation of data processing when any of the conditions provided in the data protection regulations are met.
  • To get human intervention, to express your point of view and to challenge the automated decisions adopted by LBC.
  • To request the portability of your data.


Likewise, the user is informed that at any time he/she may file a complaint regarding the protection of their personal data before the competent Control Authority.

12. Security Measures

LBC will process the User’s data at all times in an absolute confidential way and maintaining the mandatory duty to secrecy with regard to said data, in accordance with the provisions set out in applicable regulations, and to this end adopting the measures of a technical and organisational nature required to guarantee the security of their data and prevent them from being altered, lost, processed or accessed illegally, depending on the state of the technology, the nature of the stored data and the risks to which they are exposed.

13. Notices Related to Local Laws and Regulations

For more information you can view a copy of our Privacy Policy.

Special Provisions for Thai Residents:

1. For Clause 7 of the Privacy Policy “to which recipients will the user’s data be disclosed”

As the recipients indicated in this section may be located out of Thailand and also, since LBC’s centralized systems are located out of Thailand, the data collected will be transferred and processed out of Thailand. 

2. For Clause 11 of the Privacy Policy “exercise of rights”

The User may also exercise the following rights:

  • The right to suspend the processing of data
  • The right to request copies of their data collected


The following conditions only apply for the Canada market:

If you sign up for our loyalty programme, LBC, and choose to redeem your LBC points on the website or through the App, we may use your mobile phone number to send you a confirmation code to confirm your transaction before processing your points redemption. Message and data rates may apply.

Collection and Consent

To the extent required by applicable law, we will obtain your consent (separately, if applicable) to collect, use, share, transmit (including but not limited to overseas transmission), disclose or otherwise process your personal information.

Directly from You: We collect your information:

For sign up as a member of Membership programme, information collected include:

  • Nationality, name, surname, e-mail address, country of residence, phone number, date of birth
  • In order to provide a secure access to Membership Programme, we will collect username and password.


Members’ data will be processed to manage registration in the Programme and for earning and redeeming points therefore one you become a member we will process all the data related to your accommodation records, and related to the earning and redeeming points. Such information is not collected when you register but is then processed when you are a member.

For book a stay, information collected include:

  • Gender, Nationality, name, surname, e-mail address, country of residence, phone number, card data or other payment data


For register in newsletter, information collected include:

  • Nationality, name, surname, e-mail address, phone number, contact preferences


If you provide us with additional information regarding Food Allergy, Intolerances, details of preferences, Geolocation Data, we will be able to provide with you a better and personalized service.

If you provide us with personal information about other people (e.g. family members or colleagues) during your hotel reservation or stay, we ask you to ensure that they are willing to share their personal information with us and to direct them to this Privacy Policy if they would like to know how we use their information.

In addition: We automatically collect your information when you use our website, mobile applications, interact with our other digital channels and, in some cases, when we communicate with you by email. In these cases, information such as your country information, Internet protocol (“IP”) addresses, intermediate access control addresses, your interactions with these channels, and other characteristics about your system or device may be automatically collected. This information is collected to complete the functionality and improve the experience of using the services. This information is also used to aggregate trends and statistical analysis to show you more relevant ads and information.

Sensitive personal information

Certain types of personal information described in this Privacy Policy are considered “sensitive” information and subject to other applicable rules depending on the jurisdiction and applicable laws in which you work or reside. Where applicable, the personal information referred to in this Privacy Policy shall be deemed to include sensitive personal information, if any.

“Sensitive Personal Information” as defined by Chinese laws and regulations that we collect and use for the purposes set forth in the Privacy Policy above include the following information:

  • Food allergy
  • Accommodation records;
  • Location information;
  • Payment card information (used to pay for hotel stays, deposits or other services);


Children’s information

We take the protection of children’s personal information very seriously. Our website and services are mainly aimed at adults. Children should not create their own user accounts without parental or guardian consent. Although local laws and customs define children differently, we consider anyone under the age of 14 to be a child.

In the case of the collection of child user information with the consent of parents or guardians, we will only store, use or publicly disclose this information if it is permitted by law, with the express consent of parents or guardians or necessary for the protection of children, otherwise we will seek to delete the relevant data as soon as possible.

Due to the limitations of existing technology and business model, it is difficult for us to proactively identify children’s personal information. If you find that we have collected children’s personal information without our knowledge or without prior consent of verifiable guardians, you may contact us in time and we will try to delete it in a timely manner upon discovery. If we ourselves find any of the foregoing circumstances, we will also remove them in a timely manner, except for those required to be retained by law.

The exception to authorized consent

Please understand that according to laws and regulations and relevant national standards, we do not need to obtain your authorization and consent to collect and use your user information under the following circumstances:

1. Directly related to national security and national defense security;

2. Directly related to public security, public health and major public interests;

3. Directly related to criminal investigation, prosecution, trial and execution of judgment;

4. In order to protect your or other individuals’ life, property and other major legal rights and interests, but it is difficult to get the consent of the person;

5. Your user information collected is disclosed to the public by yourself;

6. Your user information collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;

7. Necessary to sign or perform the contract according to your requirements;

8. Necessary for the safe and stable operation of the software and related services, such as discovering and handling faults of the software and related services;

9. The person who controls the personal information shall be the news organization and necessary for it to carry out lawful news reports;

10. When an academic research institution conducts statistics or academic research in the public interest and provides the results of academic research or description to the public, it de-identifies the personal information contained in the results.

11. Other circumstances stipulated by laws and regulations.

How do we use the information we collect

Unless otherwise stated to you at the time of data collection, or otherwise authorized by law or by you, we use personal Information only for the purposes described in this Privacy Policy. We use the personal information collected by LBC also for the following purposes:

  • Operate, maintain, upgrade and provide all the featured services, provide you with required services and information, respond to comments and questions, and provide support for users.
  • Understand and analyze user trends and preferences, improve LBC services, and develop new products, services, features and functions. We (with your consent or as permitted by applicable law) may, based on your preference, send you commercial information through E-mail and/or traditional letters and/or SMS and/or telephone and etc. to share products, services, promotions, specials, events or other related matters with you. If you do not want to receive these promotional messages, you can opt out of receiving these promotional messages via Info@laybeachclub.com or via the withdrawal option provided in each of the commercial communications received.


Share and disclose your personal information with third parties

We may share and disclose your personal information with third parties as explained in the “To which Recipients will the User’s Data be Disclosed” section of the Privacy Policy.

In case you request to benefit from the services offered by Membership program partners (including airlines, shopping, car renting, leisure and others), we will communicate your data to such partners for the attention of your request.

We will also share your information sub-processors in order to provide you with the services according to this Privacy Policy.

In addition, we will share and disclose your personal information to the hotel in which you make a reservation for stay in order to process your booking.

Cross-country data transmission

Whereas LBC is a global hotel group, for the purposes set forth in this Privacy Policy and to achieve LBC purpose of providing you with premium and quality services worldwide, with your sole consent (if required by applicable law), your personal information will be transmitted to LBC located oversea at Calle Gremio Toneleros, number 24, Palma de Mallorca, Spain, and may be transmitted to other LBC affiliated entities or hotel entities in which you make a reservation for stay located at other countries or regions, and such affiliated entities and/or hotel entities will process your personal information for the purposes and in the manner described in this Privacy Policy. LBC will take appropriate measures to ensure that the cross-border transfer of data and the processing of your personal information by LBC overseas affiliated entities comply with the requirements of applicable law. Such mechanisms are designed to ensure adequate protection of your personal information in accordance with applicable law. If you wish to exercise your rights with respect to personal information you may contact LBC at Info@laybeachclub.com.

How we store and protect your personal information

We will store your personal information for as long as necessary to achieve the purposes set forth in this Privacy Policy, for the duration of your use of our services, and otherwise as required by applicable law. We will take reasonable security measures to protect your personal information in accordance with industry standards, and are committed to using various technologies and measures to protect your personal information from unauthorized access, use, modification, disclosure and damage of such information, such as the use of encryption technology to protect your personal information. We will handle personal information security incidents in accordance with applicable laws and regulations, and provide personal information protection training to relevant personnel to enhance their awareness of the importance of personal information and responsibilities related to personal information protection.

SDKS and other similar software technologies provided by unaffiliated entities

According to PRC laws, LBC must disclose the SDK for your acknowledgement. In the course of providing products or services, we may deploy plug-ins that are not associated with entities, such as software development kit SDK, statistical analysis tools, etc., which may collect your personal information. In order to facilitate your understanding of the SDKS of the non-associated entities we use, you can refer to the following SDK list to learn more about our integrated SDK information.

If you use these features and plug-ins provided by unaffiliated entities, the privacy policies of those entities may also apply to you. Some of these entities may collect data from you for their use and processing, and may seek your consent before doing so. In any case, we recommend that you read the privacy policies of these unaffiliated entities before using their features and plug-ins to understand how they collect and process your data.

Name of SDK Provider: Dynatrace LLC

Purpose of Collection and Use: To collect and analyze data to provide insights into the performance and behavior of applications

Personal Information Collected via SDK:

Device information:

  • Device type
  • Operating system version
  • Device language


Device ID User’s location

Sensitive Permission Requested: Location

Link to SDK Provider Privacy Policy:

https://www.dynatrace.com/support/help/manage/data-privacy-

Name of SDK Provider: Meta

Purpose of Collection and Use: to handle App Link from within the Facebook app or to handle a deferred deeplink that was sent to a user via a push notification

Personal Information Collected via SDK:

NA

Sensitive Permission Requested: Push notifications

Link to SDK Provider Privacy Policy: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

Name of SDK Provider: Salesforce, Inc.

Purpose of Collection and Use: To create personalized and targeted marketing campaigns for better engagement

Personal Information Collected via SDK:

Device information:

  • Device type
  • Operating system version
  • Device ID
  • Device language
  • Location data


Sensitive Permission Requested: Location Push notifications

Link to SDK Provider Privacy Policy: https://www.salesforce.com/es/company/privacy/full_privacy/

Name of SDK Provider: Salesforce, Inc.

Purpose of Collection and Use: To offer personalized customer support and improve customer satisfaction through efficient communication and collaboration

Personal Information Collected via SDK:

Device information:

  • Device type
  • Operating system version
  • Device ID
  • Device language


User’s information:

  • Full name
  • Reservation information


Sensitive Permission Requested: Location Push notifications

Link to SDK Provider Privacy Policy: https://www.salesforce.com/es/company/privacy/full_privacy/

Name of SDK Provider: SALTO Systems, SL

Purpose of Collection and Use: To allow users to access through a mobile app Personal Information Collected via SDK:

Reservation information:

  • Key digital


Sensitive Permission Requested: Location Bluetooth

Link to SDK Provider Privacy Policy:

https://saltosystems.com/es-es/datos-legales/privacidad/privacy-policies/salto-systems/

Name of SDK Provider: ONE2ONE DIGITAL STRATEGY, S.L.

Purpose of Collection and Use: To personalize and optimize the user experience

Information Collected via SDK:

Device’s advertising ID

Sensitive Permission Requested: Permission to Track (AppTracking Transparency) [iOS]

Link to SDK Provider Privacy Policy:

https://www.mo2o.com/politica-de-privacidad/

Name of SDK Provider: Akamai Technologies, Inc

Purpose of Collection and Use: Protecting against attacks and to improve the security of network access

Information Collected via SDK:

  •  IP address
  • device information


Sensitive Permission Requested: N/A

Link to SDK Provider Privacy Policy:

https://www.akamai.com/es/legal/compliance/privacy-trust-ce

Name of SDK Provider: Google, Inc

Purpose of Collection and Use: to identify and resolve app crashes and issues, improve app performance, and enhance the user experience

Information Collected via SDK:

Device information:

  • Device type
  • Operating System version
  • Device ID


Sensitive Permission Requested: Permission to Track (AppTracking Transparency) [iOS]

Link to SDK Provider Privacy Policy:

https://policies.google.com/privacy?hl=es-419

Name of SDK Provider: Wingify

Purpose of Collection and Use: To personalize and optimize the user experience by tracking user behavior and interactions with the app

Information Collected via SDK:

Device information:

  • Device type
  • Operating system
  • Device language
  • IP address


Sensitive Permission Requested: N/A

Link to SDK Provider Privacy Policy:

https://vwo.com/es/privacypolicy

Name of SDK Provider: Google, Inc.

Purpose of Collection and Use: To track user behavior and interactions with the app, and use this data to generate insights and improve the user experience. To deliver targeted and contextual messages to users based on their behavior and preferences.

Information Collected via SDK:             

Device information:

  • Device type
  • Operating system
  • Device language
  • IP address


User behavior data:

  • usage patterns
  • user interactions with the app


Data related to events, such as request and response payloads.

Sensitive Permission Requested: Push notifications

Link to SDK Provider Privacy Policy:

https://policies.google.com/privacy?hl=es-419

Name of SDK Provider: Google, Inc.

Purpose of Collection and Use: To track user behavior and interactions with the app, and use this data to generate insights and improve the user experience.

Information Collected via SDK:

Device information:

  • Device type
  • Operating system
  • Device language
  • IP address


User behavior data:

  • usage patterns
  • user interactions with the app


Data related to events, such as request and response payloads.

Sensitive Permission Requested: N/A

Link to SDK Provider Privacy Policy:

https://policies.google.com/privacy?hl=es-419s       

Name of SDK Provider: Google, Inc.

Purpose of Collection and Use: To deliver targeted and contextual messages to users based on their behavior and preferences.

Information Collected via SDK:

Device information:

  • Device type
  • Operating system
  • Device language
  • IP address


User behavior data:

  • usage patterns
  • clicks
  • user interactions with the app


Sensitive Permission Requested: N/A

Link to SDK Provider Privacy Policy:  

https://policies.google.com/privacy?hl=es-419

Name of SDK Provider: Google, Inc.

Purpose of Collection and Use: To deliver targeted and personalized push notifications and messages to users based on their behavior and preferences.

Information Collected via SDK:

Device information:

  • Device type
  • Operating system
  • Device language
  • IP address


User behavior data:

  • usage patterns
  • clicks
  • user interactions with the app


Sensitive Permission Requested: Push notifications

Link to SDK Provider Privacy Policy:

https://policies.google.com/privacy?hl=es-419                      

Name of SDK Provider: Google, Inc.

Purpose of Collection and Use: to monitor and optimize the performance of the app, and ensure a positive user experience

Information Collected via SDK:

Device information:

  • Device type
  • Operating system
  • Device language
  • IP address


User behavior data:

  • usage patterns
  • clicks
  • user interactions with the app

Sensitive Permission Requested: N/A

Link to SDK Provider Privacy Policy:

https://policies.google.com/privacy?hl=es-419

Name of SDK Provider: Google, Inc.

Purpose of Collection and Use: To personalize the user experience and improve engagement by delivering customized content and features to users based on their behavior and preferences

Information Collected via SDK:

Device information:

  • Device type
  • Operating system
  • Device language
  • IP address


User behavior data:

  • usage patterns
  • clicks
  • user interactions with the app


Sensitive Permission Requested: N/A

Link to SDK Provider Privacy Policy:

https://policies.google.com/privacy?hl=es-419

Mobile device permission

If you choose to use the feature to search for hotels near your location, we will require you to provide authorization to access your location information in order to run this feature.

Personalized commercial communications

In order to help you better obtain the information you are interested in, we may collect your personal information to provide you with personalized commercial communications.

If a customer wishes to stop receiving LBC commercial or promotional messages, he/she may request cancellation by (i) sending an email to the following address: Info@laybeachclub.com indicating in the email that he/she does not wish to receive such commercial and promotional information or (ii) using the withdrawal option provided in each of the commercial communications sent.

Your rights

In addition to the rights mentioned in this Privacy Policy, you also enjoy the following rights as permitted by the data protection laws of the People’s Republic of China:

  • Access your personal information and obtain a copy of the information
  • You have the right to access personal information held by us about you or to obtain copies of such information.
  • Transfer your personal information
  • You have the right to request that your personal information be transmitted to another data controller as permitted by applicable law.
  • Close your account
  • You also have the right to contact Info@laybeachclub.com  and request that we close your Membership loyalty program account.
  • The right to request deletion and correction of information

 

You may ask us to correct any incorrect information about you (see the “Exercise of Rights” section for details). We are happy to correct such information, but we need to verify its accuracy first.

If you believe that it is no longer necessary for us to use your information for the purpose for which it was collected, you may request that we delete your information. In addition, you may request us to delete your information if you have revoked your consent to our use of your information (if we originally asked you to consent to our use of your information), or have exercised your right against further lawful use of your information, or if we have used your information unlawfully, or if we are bound by legal obligations to delete your personal information.

In individual cases, we may not be able to meet your requirements. Examples of such situations include when we need to continue to use your information to fulfill our legal obligations, or when we need to use your information to establish a legitimate claim, enforce a legal right, or defend a legal claim.

The right to revoke consent to permission to use mobile devices

You can revoke authorization or consent to use of the mobile device in the Settings options for the device.

To exercise any of the above rights, you can also contact us by sending an email to Info@laybeachclub.com.

We aim to respond to all valid requests for exercising the above rights within 15 working days after verifying your identity. In order to be able to respond more quickly, we may ask you to provide more detailed information related to your inquiry.

In individual cases, we may not be able to comply with your request, for example, your request may affect our duty of confidentiality to others, or we may be legally entitled to handle your request differently.

Privacy policy update

LBC reserves the right to update or modify this policy from time to time. If our privacy policy changes, we will post the latest version of the privacy policy here. If we make a material change to our privacy policy, we may also notify you of the change through various channels, for example, by posting a notice on our website or by posting a separate notice to you.