Privacy Intro
Effective Date: January 1, 2020
Last Updated: July 1, 2023
The Privacy Policy describes how Insight Global, LLC and its affiliated entities (“Insight Global” “we” and “us”) process personal information about you. This Privacy Policy applies when you visit or use our websites or mobile applications (each a “Site” and collectively “Sites”), contact our customer service team, engage with us on social media, communicate with us on behalf of a vendor or client, purchase our products or services, or otherwise interact with us.
This Policy does not apply to personal information processed in connection with applications to work for Insight Global as part of our in-house team or to personal information collected in the course of your employment as part of our in-house team. Our In-House Privacy Notice applies to that personal information.
The Policy also does not apply to personal information that we process in connection with a candidate’s application to or appointment as an consultant to fulfil roles for Insight Global’s clients or companies that we represent. Our Candidate Privacy Notice applies to that personal information.
By using the website, you are consenting to this Privacy Policy. Please read it carefully. If you have any questions, please contact us as provided below. You may download a copy of this Privacy Policy by clicking here.
Contents
Categories of Personal Information We Collect
Sources Of Personal Information
Purposes for Collecting Personal Information
How We Share Personal Information
We Combine Information
Sensitive Personal Information
How Long We Keep Personal Information
Cookies, Analytics, and Other Tracking Technology
Links to Other Websites
Security
This Website is Not Intended for Children
Marketing Communications
Processing in the United States and Canada
California Privacy Rights/Notice to California Residents
Nevada Privacy Rights
Virginia, Colorado, and Conneticut Privacy Rights
Canada Privacy Rights
Contact Us
Updates to Our Privacy Policy
Categories of Personal information
Categories of Personal Information We Collect
We collect the following categories and types of personal information with your consent or as otherwise required or permitted by law:
- Contact Information. We collect full name, email address, current and prior address, telephone number, and business contact information.
- Identifiers. We collect Internet protocol address, signature, username and password, and social media user names.
- Personal Characteristics or Traits. We collect date of birth, gender, age, nationality, racial or ethnic origin, religion, marital status, citizenship status, military or veteran status and disability information.
- Financial Information. We collect tax identification number, financial or bank account information, tax-related information, wire instructions, payment card number, payment card expiration date and CVV code, card or account security details, and billing address.
- Commercial Information. We collect records of products or services purchased, obtained, or considered.
- Internet or Electronic Usage Data. We collect data related to network and website interaction history, IP address, website cookie information, interaction with advertisements and browsing time.
- Audio/Visual Data. We collect audio, electronic, photographic, visual or similar data including videos, photographs, or audio recordings.
- Geolocation Data. We collect geolocation data including the general region or area from which you access our Sites.
- Professional or Employment Information. We collect your job title, office location, business contact details, and company entity when you contact us on behalf of a third-party.
- Inferences: We use information from the categories of personal information described above in order to create a profile about you, to reflect your preferences, characters, behavior and attitude.
Sources of Personal information
Sources of Personal Information
We collect information in a variety of ways:
- Directly from you. We collect contact information, identifiers, financial information, commercial information, and professional or employment information that you provide directly to us.
- When you visit our locations. When you visit our offices or facilities, we also collect contact information and audio/visual data.
- Automatically. When you access our Sites, we collect identifiers, geolocation data, and internet or electronic usage data using tools like browser cookies
- From third parties: We may collect contact information, identifiers, financial information, commercial information, and professional or employment information from third-parties including our vendors, clients, and service providers.
- Social media platforms. Depending on the information you choose to share and your privacy settings, we may collect contact information, identifiers, audio/visual data, personal characteristics or traits, geolocation data, commercial information, professional or employment information, internet or electronic usage data, and inferences. Based on the way you have set your privacy settings on your social media accounts, most social media platforms, like Facebook and Instagram, analyze data about how you interact with our Sites and combine it with information on other users to provide us information about you. In addition, we may receive information about you if other users interact with us on social media and information about you is visible to us, for example the fact that you are “friends” or other public-facing profile information.
purposes for collecting information
Purposes for Collecting Personal Information
We use your personal information for the following purposes:
- Transactional Purposes. We use contact information, identifiers, financial information, professional or employment information, and commercial information to: (i) provide you or our clients with products and services that we offer; (ii) communicate with you; (v) provide you with customer assistance; and (vi) provide supporting business activities such as billing and collections, procurement, and tax related activities.
- Analytical Purposes. We use identifiers, internet or electronic usage data, geolocation data, commercial information, and inferences to analyze preferences, trends and statistics.
- Marketing and Promotional Purposes. We use contact information, identifiers, financial information, professional or employment information, internet or electronic usage data, geolocation data, and inferences to improve our marketing efforts, conduct market research, prospect for new clients or consultants, client relationship management, client engagement, administering promotions, and to provide you with information about us, including personalized marketing communications.
- Maintenance and Improvement of our Sites and Systems. We use identifiers, geolocation data, internet or electronic usage data to improve our Sites and systems, provide and maintain functionality on our Sites and systems, and help us diagnose technical and service problems and administer our Sites and systems.
- Develop and Improve Our Products and Services. We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to help us develop new products and services and to improve and analyze our existing products and service offerings.
- Security and Fraud Prevention. We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to: (i) protect our Sites, premises, assets, systems, products, services and intellectual property; (ii) protect us, our affiliated companies, our employees, our carriers and others from fraud, theft and other misconduct; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
- Legal: We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
- Other Purposes: We may use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information for other reasons we may describe to you.
We Combine Information
We Combine Information
We combine information we obtain from different sources with publicly available information, including to create inferences about you. For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third party sites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.
Sensitive Personal Information
Sensitive Personal Information
Unless specifically requested, we ask that you not send us, and you not disclose to us, through the Services or otherwise, any Sensitive Personal Information (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).
How Long We Keep Personal Information
How Long We Keep Personal Information
We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to request that we no longer use your information to provide you services or products, please contact us at [email protected].
Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in future.
We use the following criteria to determine retention periods:
- how long the information is needed to provide our services and operate our business;
- whether there are contractual or legal obligations that exist that require us to retain the information for period of time
- whether any law, statute, or regulation allows for a specific retention period;
- whether an individual has agreed to a longer retention period;
- whether the data is considered to be sensitive data, and
- what the expectation for retention was at the time the data was provided to us.
Cookies, Analytics, and Other Tracking Technology
Cookies, Analytics, and Other Tracking Technology
Cookies and Tracking Technology
We want you to be aware that certain online tools exist to help us serve and recognize you when you visit our website. We receive and store certain types of information when you visit our website. When you access the website, we (including companies we work with) may place small data files on your computer or other device. These data files may be web beacons, cookies, clear gifs, pixel tags, e-tags, flash cookies, log files, or other local storage provided by your browser or associated applications. These tracking technologies, which are often referred to collectively as cookies, allow us to understand how users navigate to and around our website, view different pages, access content and request Services. We may use them, for example, to keep track of your preferences and profile information and collect general usage and volume statistical information. If you want to remove or block cookies, you may be able to update your browser settings. You can also find instructions on how to manage cookies on different types of web browsers at www.allaboutcookies.org. Please click here to change your preferences regarding cookies.
Cross-Contextual Behavioral Advertising and Targeted Advertising
We allow third-parties to provide analytics and advertising services and serve advertisements on our behalf across the Internet and in mobile applications. Our advertising partners may collect information about your activities on our Sites on your current device and combine it with information about your activities on other websites, mobile apps, and devices. They may also collect IP address, browser or operating system type and version, and demographic or inferred-interest information, as well as personal information if you have submitted such information to us through the Sites, such as your name, postal address, email address, or device ID. They collect such information using server logs, cookies, web beacons, tags, pixels, mobile advertising IDs (such as Facebook cookies or Google’s Advertising ID), cross-device linking, and similar technologies. For example, our advertising partners may use the fact that you visited our website to target advertising to you on other websites and mobile apps on your current device or on other devices you use. They may match your browsers or devices if you log into the same online service on multiple devices or if your devices share similar attributes that support an inference that they are used by the same person or household. This means that information about your activity on websites or apps on your current browser or device may be combined and used with information collected from your other browsers or devices. These third parties partners use this information for our and their own advertising, analytics, attribution, and reporting purposes. To learn more about interest-based advertising, tracking technologies, and how to opt out, please visit http://www.aboutads.info/choices. You can disable the sharing of your personal information for cross-contextual behavioral advertising or targeted advertising through online cookies and tracking technology by clicking here and changing your cookie preferences to ensure that Analytics and Advertising cookies are disabled.
Session Replay Technology
We use session replay technology on our Sites. Session replay technology, also referred to as session playback or user experience (UX) replay, collects information regarding, records, and tracks your interactions with a website or application. It then and transforms those logged user events (such as mouse movements, clicks, page visits, scrolling, tapping, etc.) into a reproduction of what you actually did on the website or application. We use session replays for quality control, customer service, fraud prevention and security, and marketing purposes. Our session replay technology is owned and operated by a third-party who acts as our service provider. The information collected by this technology may be collected by, transferred to, and stored by our third-party service provider.
ChatBot Technology
We use chatbots to help provide customer service and support, including through the use of a virtual assistant. A chatbot is a software application that mimics human conversations in text or voice interactions on our website or through our customer service hotline. It enables the communication between a human and a machine, which can take the form of messages or voice commands. The chatbot is designed to work without the assistance of a human operator. It responds to questions posed to it in natural language as if it were a real person using a combination of pre-programmed scripts and machine learning algorithms. When asked a question, the chatbot will answer using the knowledge database that is currently available to it. If the conversation introduces a concept it isn’t programmed to understand; it will pass it to a human operator. If you use our chatbot service, we will collect any personal information you provide to use. We will also create and store a transcript of your chat interaction with us which will be shared with and stored by our third-party service provider. We use these transcripts and the information you provide for quality control, customer service, fraud prevention and security.
Global Privacy Control and Opt-Out Preference Signals
Some browsers or browser extensions also allow you to tell websites not to share your information for cross-contextual behavioral advertising through the “global privacy control” or other opt-out preference signals. We will respond to these signals in a frictionless manner. Please note that we may not be readily able to associate an opt-out preference signal with other personal information such as your email address. If you configure this setting on your browser, certain features on our site may not work and you will receive less targeted advertising. You will also need to turn the setting on for each browser that you use.
Do Not Track Signals
Some browsers have a “do not track” feature. It lets you tell websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.
Google Analytics
We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit www.google.com/policies/privacy/partners. If you would like to opt-out, Google provides a an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.
Links to Other Websites
Links to Other Websites
Our Sites may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or application that you use.
Security
Shopify, Shop, and Pay
We use Shopify to power our online store – Shop IG. When you create an account, provide your personal information to Shopify, or use Shopify’s apps and services, Shopify will process your personal information. Shopify’s processing of your personal information will be governed by Shopify’s privacy policy, which is available at https://www.shopify.com/legal/privacy/app-users. When you use Shop or another Shopify app to make a purchase, Shopify will share your personal information with us. We will process the personal information we receive from Shopify in accordance with this Privacy Policy.
Security
Security
We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.
This Website is Not Intended for Children
This Website is Not Intended for Children
We do not knowingly collect or store any personal information from anyone under the age of 13. If we become aware that we have collected or stored personal information from an individual under age 13, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to [email protected]
Marketing Communications
Marketing Communications
Marketing Emails. You can opt out of marketing or advertising emails by using the “unsubscribe” link or mechanism noted in communications you receive from us. You may also request to opt out of marketing or advertising emails by contacting us at [email protected]. Once we process your request, we will cease using the information for such purposes at no charge to you. If you opt out of getting marketing messages, you will continue to receive messages from us about your relationship with us where permitted by law.
Phone Calls and Text Messages. If you do not want to receive marketing phone calls or text messages from us, please inform us that you no longer want to receive calls from us when you receive a call from us, or reply STOP to a text message from us. You can also opt-out of telemarketing by contacting us at [email protected].
Processing in the United States and Canada
Processing in the United States and Canada
Please be aware that information we obtain about you will be processed in the United States and across Canada by or service providers or us. By using the Sites or our services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States, Canada or other jurisdictions may be different from the laws in your country of residence. The United States may not afford the same level of protection as laws in your own country.
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California Privacy Rights/Notice to California Residents
California Privacy Rights/Notice to California Residents
Shine The Light. If you are a California resident, this section applies to you. The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at [email protected] and include “CA Shine the Light” in the subject line of your email.
California Consumer Privacy Act.
Categories, Sources, and Uses of Personal Information We Collect. In the preceding 12 months, we have collected the following categories of personal information: contact information, identifiers, financial information, commercial information, internet or electronic usage data, geolocation data, professional or employment information, audio/visual data, personal characteristics or traits, and inferences. For details about precise data points we collect, the categories of sources of such collection, and the business and commercial purposes for collecting personal information, please see the sections above titled Categories of Personal Information We Collect, Sources of Personal Information, and Purposes for Collecting Personal Information.
Use or Disclosure of Sensitive Personal Information. In the preceding 12 months, we have not used or disclosed sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.
Sale or Sharing of Personal Information. In the preceding 12 months, we have “sold” or “shared” (as those terms are defined in the CCPA) identifiers, commercial information, internet or electronic usage data, geolocation data, and inferences to marketing/analytics/advertising partners. We do not knowingly sell or share the personal information of minors under the age of 16.
Disclosure for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information to the following categories of third party recipients:
| Category of Personal Information | Categories of Recipients |
|---|---|
| Contact Information |
|
| Identifiers |
|
| Financial Information |
|
| Commercial Information |
|
| Personal Characteristics or Traits |
|
| Geolocation Data |
|
| Internet or Electronic Usage Data |
|
| Professional or Employment Information |
|
| Audio/Visual Data |
|
| Inferences |
|
For a more expansive description of the categories of recipients and business purposes for which we share personal information, please see the How We Share Personal Information section above.
Your Rights Under the CCPA. Subject to certain exceptions and limitations, the CCPA affords California consumers the following rights:
- You have the right to request that we tell you (i) the categories of personal information we have collected, sold, or shared about you, (ii) the sources of that information, (iii) the business or commercial purposes for collecting, selling or sharing the personal information; and (iv) the categories of third-parties to whom we have disclosed, sold or shared personal information.
- You have the right to request that we provide you with a copy of your personal information.
- You have the right to request that we delete personal information that we have collected from you.
- You have the right to opt-out of the sale or sharing of your personal information.
- You have the right to opt-out of the sharing of your personal information for cross-contextual behavioral advertising.
- You have the right to direct us to limit the use or disclosure of your sensitive personal information to only the purposes specified in the CCPA
- You have the right to correct inaccurate personal information that we hold about you.
- You have the right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.
Exercising Your Rights. To exercise any of your CCPA rights, please use our webform or call us toll free at 1-833-742-0828. For all requests, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request.
If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.
In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us at [email protected].
Cookie Based Opt-Outs for Do Not Sell or Share for Cross Context Behavioral Advertising
We engage in online advertising practices (and certain analytics or similar activities), which may be considered a “sale” or “share” for cross-context behavioral advertising. In addition to submitting the form above, you may need to disable sharing through cookies set by third parties on our Sites. To manage your cookie preferences, please click here and ensure that Analytics and Advertising cookies are disabled
If you have enabled Global Privacy Control or an opt-out preference signal on your browser or extension, we will honor such requests that can be recognized by our Sites by disabling Analytics and Advertising cookies Please note that we may not be readily able to associate an opt-out preference signal with other personal information such as your email address. You will also only be opted out of online sales or sharing of personal information, and will need to turn it on for each browser you use. Refer to the “Exercising Your Rights” above if you would like to extend your opt-out request beyond the online advertising practices described above.
Other Consumer Rights Information. Under California Civil Code Section 1789.3, we are required to provide California residents with the following information:
- Unless otherwise expressly stated, this Site is provided without charge.
- To file a complaint regarding this Site or to receive further information regarding use of this website, please contact us via email at [email protected]. You also may contact the Complaint Assistance Unit of the Division of Consumer Services of California’s Department of Consumer Affairs in writing at 400 R Street, Suite 1080, Sacramento, California 95814 or by telephone at (916) 445-1254 or (800) 952-5210.
Removal of Content. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to [email protected]. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
Nevada Privacy Rights
Nevada Privacy Rights
If you are a Nevada resident, you may request that we stop selling certain categories of personal information that we collect. We do not currently sell your personally identifiable information as those terms are defined under Nevada law. However, if you wish to submit a request to opt-out of the sale of such information if we were to engage in such a sale in the future, you may submit your request in writing using our webform or emailing us at [email protected]. For all requests, you must provide us with your name, email address, phone number, and mailing address so that we can verify your identity by matching the information we have collected against the information you have provided. Failure to provide all of the foregoing information may prevent us from processing your request.
Virginia Privacy Rights
Virginia, Colorado, and Connecticut Privacy Rights
This section applies to you if you are a resident of Virginia, Colorado, or Connecticut
We set forth in our Privacy Policy the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared.
Your Rights. Consumers in certain states, including Virginia, Colorado, and Connecticut, may have the following rights with respect to their personal data:
- You have the right to request that we confirm whether or not we are processing your personal data and to access your personal data.
- You have the right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format to allow data probability
- You have the right to correct inaccurate personal data that we hold about you, taking into account the nature of the personal data and the purposes of the processing of the data.
- You have the right to request that we delete personal information that we have collected from you or obtained about you.
- You have the right to opt out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Exercising Your Rights. To exercise any of your rights, please use our webform or call us toll free at 1-833-742-0828. For all requests, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request.
If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.
In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization to us at [email protected].
Appealing Our Decision. If we refuse to take action on your request, you may appeal our decision within a reasonable period of time, not to exceed 90 calendar days from the date of your receipt of our response. You may exercise your appeal rights by emailing us at [email protected]. Please include your full name, the basis for your appeal, and any additional information to consider.
Cookie Based Opt-Outs for Cross Context Behavioral Advertising
We engage in online advertising practices (and certain analytics or similar activities), for targeted advertising and cross-context behavioral advertising. To turn off targeted and behavioral advertising through cookies, please click here and ensure that Analytics and Advertising cookies are disabled. Please note that we may not be readily able to associate your personal information with your IP address or Device ID.
If you have enabled an opt-out preference signal on your browser or extension, we will honor such requests that can be recognized by our Sites by disabling Analytics and Advertising cookies. Please note that we may not be readily able to associate an opt-out preference signal with other personal information such as your email address. You will also only be opted out of online targeted advertising or cross-context behavioral advertising, and will need to turn it on for each browser you use. Refer to the “Exercising Your Rights” above if you would like to extend your opt-out request beyond the online advertising practices described above.
Canada Privacy Rights
Canada Privacy Rights
Your Rights. If you are a resident of Canada, subject to certain exceptions and limitations, you have the following rights:
- You have the right to request that we inform you of the existence, use, and disclosure of your personal information and provide you with a copy of that personal information within the timeframes provided for by law.
- If the personal information we hold about you is inaccurate or incomplete, you have the right to have it rectified.
- You have the right to contact us to request information about our data processing activities, namely what personal information was collected from you and how we process it. You may ask us to clarify the categories of third-parties that have access to your personal information and the applicable retention period for that information.
- You have the right to withdraw that your consent to our collection, use, and disclosure of personal information at any time. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Exercising Your Rights. To exercise any of your rights, please use our webform or call us toll free at 1-833-742-0828. For all requests, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request.
Contact Us
Contact Us
If you have any questions about this Policy or our data practices, please email us at [email protected] . You can also write to us at:
Insight Global
Attention: Data Privacy Officer
1224 Hammond Drive, Suite 1500
Atlanta, Georgia 30346
Updates to Our Privacy Policy
Updates to Our Privacy Policy
From time to time we may change our privacy policy. We will notify you of any material changes to our privacy policy as required by law. We will also post an updated copy on the website where this appears. Please check our website periodically for updates. The “Last Updated” legend above indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on any of our Sites.