March 2020

Your privacy is important to us. This Privacy Policy explains how we handle and treat your personal data when you (i) register or visit our site, www.vlantoiu.ro (the “Site”) or (ii) engage with us to use the products or services that Vlănțoiu și Asociații provides (our “Services”) or (iii) apply for a position within our company or (iv) provide us with goods or services or you act as a representative, employee or any agent of a company that provides us with goods or services; or (v) have your data processed by us when providing our legal services, as required by the court of law or third parties.

  1. Purpose of this Policy
  2. Who are we and what do we do
  3. How to contact us
  4. What personal data do we collect
  5. How do we use your personal data
  6. What is our legal basis to use or process your personal data
  7. Who do we share your personal data with
  8. Our use of cookies and similar technologies
  9. Third party contractors and other controllers
  10. Where do we transfer your data to
  11. How long do we keep your personal data for
  12. Confidentiality and the security of your personal data
  13. How to access your data and your other rights
  14. Changes to this Privacy Policy

1. Purpose of this Policy
This Privacy Policy (“Privacy Policy”,”Policy”) explains our approach to any personal data that we collect from you or which we have obtained about you from a third party and the purposes for which we process your personal data. It also sets out your rights in respect of our processing of your personal data.
This Privacy Policy will inform you of the nature of your personal data that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it.
In this Privacy Policy we use the term “processing” to cover all activities involving your personal data, including the collection, handling, storage, sharing, access, use, transfer and removal of data.
This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services, to understand how your personal data may be processed by us as a result of providing the Services or when you apply to work at or with Vlănțoiu și Asociații. Please take a moment to read and understand it.
Please also note that this Privacy Policy only applies to the use of your personal data obtained by us.

2. Who are we and what do we do
Vlănţoiu şi Asociaţii, hereinafter referred to as the “Company” or “We”, is a law firm that provides legal services to clients in accordance with the relevant laws of Romania and of the European Union, located in bd. Unirii nr. 45, bl. E3, sc. 5, et. 8-9, ap. 141, Bucharest, sector 3, legally represented by Mrs. Andreea Vlănţoiu, as a Managing Partner.
Vlănţoiu and Asociaţii is part of a global lawyer’s network, Linet SRL (Limited) C.F. / P.IVA 10187800965 – REA MI – 2511888, Via Roald Amundsen 5 20148 Milan, represented legally by Mr. Pierangelo Grassi. LINET does not itself provide legal or other services to customers.

3. How to contact us
If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by sending an email to: privacy@vlantoiu.ro.

4. What personal data do we collect
We may collect personal data from you in the course of our business, including through your use of our Site, when you contact or request information from us, when you engage our legal services or as a result of your relationship with one or more of our staff or clients. Both our Site and our Services are addressed to people over the age of 18, so we do not intend to collect and process through our Site data from people under this age.
Our primary goal in collecting personal data from you is to help us:

  • verify your identity
  • deliver our Services
  • improve, develop and market new Services
  • carry out requests made by you on the Site or in relation to our Services
  • investigate or settle inquiries or disputes
  • comply with any applicable law, court order, other judicial act, or the requirements of a regulator
  • enforce our agreements with you
  • protect the rights, property or safety of us or third parties, including our other clients and users of the Site or our Services
  • with recruitment purposes, and
  • use as otherwise required or permitted by law.

To undertake these goals, we may process the following personal data:
a) If you are a visitor to the Site:

  • Information obtained through cookies, such as: site display preferences, selected language, consent to cookie data processing, or information that cannot be used to identify you with a unique profile but may be used by Google Analytics and Google AdWords for advertising purposes
  • All information about the cookie used on our site is contained in the ‘Cookie Policy‘

b) If you are a visitor to the site and contact us using the contact form on the site:

  • Name, surname
  • Contact information (email address, phone number)
  • Other information you choose to provide via the “Message” field in the contact form
  • Information obtained through cookies, according to the section “Cookie Policy“

c) If you interact with us through social media networks

  • First name, last name
  • Social media and online platforms profile data (nickname, photo, biography)
  • Social networking message content, reviews, ratings, location data

d) If you are an individual client in receipt of our Services or prospective individual client:

  • Basic information such as your name, the company you work for, your position and your relationship to a person
  • Contact information such as your postal address, email address and telephone number(s)
  • Financial information, such as payment related information
  • Identification and background information provided by you or collected as part of our business acceptance policy
  • Special categories of personal data, such as information about a person’s physical or mental health, alleged criminal activities, or similar where this is necessary in connection with the Services we provide (for example, to advise on a personal injury claim or in connection with a criminal prosecution)
  • Photographs, audio and / or video recordings taken in or in connection with certain legal procedures
  • Relevant information as required by Know Your Client and/or Anti-Money Laundering regulations. This may possibly include evidence of source of funds, at the outset of and possibly from time to time throughout our relationship with clients, which we may request and/or obtain also from third party sources. The sources for such verification may comprise documentation which we request from you or through the use of online sources or both
  • Information you provide to us for the purposes of attending meetings and events, including dietary requirements which may reveal information about your health or religious beliefs
  • Any other personal information relating to you or other third parties which you may provide to us for the purpose of receiving our Services

We use this information to facilitate the provision of our Services to you, the client.  In addition, we will process identification and background information as part of our business acceptance, finance, administration and marketing processes, including anti-money laundering, conflict, reputational and financial checks, and to fulfil any other legal or regulatory requirements to which we may be subject. The information our clients provide may be disclosed to third parties to the extent that is reasonably necessary in connection with that work (for example, when seeking advice from external counsel or experts)
For clients and prospects, we also collect data to enable us to market our products and Services which may be of interest to you. For this purpose, we may collect:

  • Name and contact details
  • Other business information such as job title and the company you work for
  • Areas or topics that interest you
  • Additional information may be collected such as events you attend and if you provide it to us, dietary preferences which may indicate data about your health or religious beliefs

If we ask you to provide any other personal information not described above, the personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point that you are asked to provide your personal information.
e) If you are a potential recruit to join Vlănțoiu și Asociații:
Vlănțoiu și Asociații collects data from and about candidates in connection with available employment or collaboration opportunities at Vlănțoiu și Asociații.  This information may include CVs, identification documents, photographs, academic records, trainings or certifications obtained, work history, employment and references.
Vlănțoiu și Asociații uses your personal data to match your skills, experience and education with the specific roles offered by the firm.  This information is passed to the relevant hiring managers and persons involved in the recruitment process to decide whether to invite you for interview.  Vlănțoiu și Asociații will collect further data from you if you are invited to the interview (or equivalent) stage and onwards.
In connection with our recruitment activities, we may also collect special categories of personal data from candidates where we have an employment law obligation to do so, the information is relevant to their future working environment at Vlănțoiu și Asociații or the future provision of employment benefits, or with the individual’s explicit consent.  For example, we may need to collect information about a candidate’s disabilities in order to provide a suitable working environment for that candidate if they are successful in their application.
Vlănțoiu și Asociații may collect personal data about candidates from the following sources:

  • Directly from you – for example, information that you have provided when applying for a position directly, through the firm’s website or by using our mailing address
  • From recruitment agencies – for example, when a recruitment agency contacts us to identify you as a potential candidate
  • Through publicly available sources online – for example, where you have a professional profile posted online (e.g. on your current employer’s website, a recruitment platform or on a social networking site like LinkedIn)
  • By reference or word of mouth – for example, through a reference from former employee/employer or from a referee who recommended you

f) If you provide us with goods or services or you act as a representative, employee or any agent of a company that provides us with goods or services (“the Supplier”)
In the course of our relationship with our suppliers, we may receive personal data such as data relating to any of the officers or staff of our corporate suppliers or potential suppliers, any seller or buyer or personal data relating to their legal advisors or staff or other similar data.
The processed data about these Persons are usually the name, surname, telephone number, email, position and / or relationship with the Supplier, any identification data from any authorization granted by the Supplier, necessary data for the settlement of complaints, which, in addition to a complaint identifier, are usually limited to the type of data mentioned above. Other types of data transmitted by the Supplier may be processed as required.
g) You have your data processed by us when providing our legal services, as required by the court of law or third parties
If you are an individual whose personal data is processed by us as a result of providing the Services to others (including individual clients and corporate clients) or as required by the court of law or by third parties, we will process a variety of different personal data depending on the Services provided.
This may include personal data relating, without limitation, to any of our corporate clients’ or prospective clients’ officers or personnel, any opponent or vendor or purchaser personal data including personal data relating to their legal advisors, other advisors or personnel as relevant or similar.
We might also need to process personal data in relation to other third parties instructed either by our own clients or other persons or companies involved with us providing the Services to our client (for instance other law firms, experts etc.).
This is a non-exhaustive list which is reflective of the varied nature of the personal data processed as part of a law firm providing legal services.
The Data Subjects in this section will not be informed in any other way than by this Privacy Policy (i) if we process your personal data as a result of providing services to third parties and personal data must remain confidential under statutory professional secrecy obligations governed by Union law or Member State law including a legal obligation to keep secret; or (ii) if we process your personal data at the court’s instructions, where the obtaining or disclosure of the data is expressly provided by Union or Member State law to which the controller is subject or iii) the obtaining or disclosure of data is expressly provided by Union or Member State law to which the controller is subject.
h) Data processed by third parties

  • Data processed through social networks plugins. We inform you that by accessing our site, third parties may collect data about you as a result of integrating social media plugins, such as “Like” and “Share” buttons, even if you have not pressed them or you are not a member of the respective social networks. Our company is not involved in any way in the data processing operations by the social networks, except for collection and transmission, which take place automatically, without us having access or control over the data collected by the social networks. For more information please consult the privacy policies of the social networks whose plugins appear on our website (Facebook, Linked In etc).
  • External links. Our site may contain links to third party sites. We provide these links as a facility, and our company does not control and is not responsible for the privacy practices or the content of these sites. The responsibility for the processing of your personal data by these third parties lies entirely with them. Please, before accessing these sites, review their privacy policy and terms of use to ensure that your data is processed according to your expectations.

5. How do we use your personal data
We may use your data for the following purposes:
a) Fulfilment of Services and client services
We collect and maintain personal data that you submit to us during your use of the Site and/or our Services to enable us to perform the Services.
Our Site uses various user interfaces to allow you to request information about our Services including electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, but you are invited to send via email other details of other personal data that is relevant to your Service enquiry. This information is used in order to enable us to respond to your requests.

What is our legal basis?

It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you. Failure to provide these data automatically leads to the impossibility of concluding and / or executing the contract.
b) Business administration and legal compliance
We use your personal data for the following business administration and legal compliance purposes:

  • to comply with our legal obligations (including Know Your Client/ Anti-Money Laundering, the obligation to keep professional records, the instructions of the court of law or other authority or the provisions of a judicial decision or administrative or similar act) or similar obligations
  • to enforce our legal rights
  • in connection with a business transaction such as a merger, or a restructuring, or sale
  • in connection with the participation in a public procurement procedure
What is our legal basis?

If we use your personal data to comply with our legal obligations, we do so precisely because it is our legal obligation to use your personal data for that purpose. Where we use your personal data to exercise our legal rights, in connection with a business transaction or in connection with a participation in a public procurement procedure, it is in our legitimate interest or the interest of a third party to do so.
c) Providing legal services to our Clients:
We use your personal data for the following activities when providing legal services to our Clients

  • legal advice
  • participation in negotiations, mediation, transactions
  • fiduciary activities
  • assistance, representation before a court of law or arbitration, or before any public institution or private person
  • drafting, attestation, transmission, recording of documents, archiving, mail transmission;
  • factual or legal checks
  • to protect the rights of third parties
  • taking any necessary legal action during the provision of the Services to our Clients

Please note that certain personal data will become public when your documents are filed with the relevant public entity, such as the Cadastre and Real Estate Publicity Office, the Electronic Archive of Real Safeguards, the Trade Registry, the National NGO Register, State Office of Inventions and Trademarks etc. – the name of the owner, shareholders, directors, founders, representatives, trustees, other corporate officers or members of statutory bodies etc., all become public information when the supporting documents are submitted to the specific entity vested by law. Sometimes the public entity will provide this information to third parties for a fee.

What is our legal basis?

When we use personal data to provide Legal Services to our Clients or to protect the rights of third parties, we do so in the performance of a task that is in the public interest.
d) Recruitment
We use your personal data for the following recruitment purposes:
We use your personal data to assess your suitability for any position you may apply for at Vlănțoiu și Asociații, including partner positions, collaborator, co-worker, associated positions, trainee or practice training contract, employee, apprentice, intern, as well as any administrative or service provision, whether such application was received online, on paper or as an application in person.

What is our legal basis?

If we use your personal data in the recruitment process, it is in connection with the fact that it is our legitimate interest to analyse your application to assess your suitability for any position you may apply for at Vlănțoiu și Asociații.
If we use your personal data as part of the process of employment or concluding a collaboration, it is related to the fact that we are acting at your request to conclude a contract that we may have with you. The failure to provide this information leads automatically to the impossibility of concluding and / or executing the contract.
In connection with our recruitment activities, we can also process special categories of personal data from candidates when:

  • processing is required to meet our specific employment obligations (health data, for example)
  • you have given explicit consent to the processing of this personal data (e.g. data about a candidate’s disabilities, to provide a suitable work environment for that candidate if recruited)
  • processing refers to personal data that is manifestly made public by you (e.g. sexual orientation, philosophical or religious beliefs)
  • we can process data on criminal convictions and offenses when processing is authorized by Union or Member State law which provides adequate safeguards for the rights and freedoms of data subjects. View the Recruitment-specific Privacy Notice

e) Marketing communications
We can do email marketing or direct marketing activities by using your personal data.
We may use the information we observe about you from your interactions with our site, our email communications to you and/or with Services to send you marketing communications.
Our communications are specifically intended to inform you of legal topics that may be of interest to you.

What is our legal basis?

It is in our legitimate interest to use personal data for marketing purposes.
f) Client insight and analysis
We may analyse your contact details with other personal data that we observe about you from your interactions with our Site, our email communications to you and/or with our Services such as the Services you have viewed.
We use cookies to give you a personalized browsing experience and use of our Site or services. These are generally text files, modules or similar technologies that your computer, tablet, or mobile phone’s browser can store when you visit our site.
Files of this type have retention times and remain passive, malware-free and do not access information on your hard drive. These types of files can be accessed only by the webserver that placed them.
Information contained in cookies may include the following:

  • IP address to monitor traffic and site usage volume
  • device type or browser type used
  • a session ID to track usage statistics on our site
  • display or navigation preferences
  • information about your personal or professional interests
  • demographic data of a general nature that cannot uniquely identify you
  • past experience with our products and services, including the Site (for example, the Site pages you’ve visited)
  • contact preferences
  • preferences regarding cookies
  • preferences for marketing or advertising communication

Cookies allow us to count the users who visited a page and collect other types of aggregated information, such as the pages or types of content that were the most interesting for you.
By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors and which parts of our Site are the most interesting.
We can also use this information for marketing purposes (for more details, see the marketing section above).
Please see our cookie policy for further information.

What is our legal basis?

Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data in such a way to ensure that we provide the very best products and services to you and our other clients.

6. What is our legal basis to use or process your personal data
It is necessary for us to use your personal data;

  • to perform our obligations in accordance with any contract that we may have with you
  • it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Services in the best way that we can
  • it is our legal obligation to use your personal data to comply with any legal obligations imposed upon us
  • to perform a task carried out in the public interest

It is possible to process special categories of data when providing our services when:

  • processing is required to meet our specific employment obligations (health data, for example)
  • you have given explicit consent to the processing of this personal data (e.g. data about a candidate’s disabilities, to provide a suitable work environment for that candidate if recruited)
  • processing is necessary to establish, exercise or defend a legal claim (data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health or data concerning a natural person’s sex life or sexual orientation)
  • you have given explicit consent to the processing of this personal data (data on dietary preferences that may indicate your health or religious beliefs, for example)
  • processing refers to personal data that is manifestly made public by you (e.g. sexual orientation, philosophical or religious beliefs)

We may process data relating to criminal convictions and offenses in the course of providing our Legal Services when processing is authorized by Union or Member state law that provides adequate safeguards for the rights and freedoms of data subjects.

7. Who do we share your personal data with
Vlănțoiu și Asociații may share personal data with a variety of the following categories of third parties as necessary:

  • our professional advisers such as lawyers and accountants
  • government or regulatory authorities, tax authorities
  • public registers such as the Trade Registry, the National Register of NGOs, the Electronic Archive for Security Interests in Movable Property, the Office for Cadastre and Real Estate Advertising, the State Office of Inventions and Trademarks etc., the Electronic Register of Attorney-attested Documents, the Official Register of Legal Assistance Contracts, the Electronic Register of Lawyers’ Dedicated Assets Records or similar
  • third parties engaged in the course of the services we provide to Clients such as consultants, arbitrators, mediators, clerks, notaries public, bailiffs, witnesses, court, opposing parties and their lawyers, document and activities review or management platforms, experts such as tax advisors or valuers
  • third parties to whom we outsource certain services, such as, without limitation, consulting services of various specialties, document processing and translation, secretarial services, confidential waste disposal, audit, training, IT systems or software providers, IT support service providers, document and information storage providers, cloud providers, marketing and PR agencies, advertising and advertising production, event organization, human resources and payroll companies, security companies and building management bodies, delegates, postal or courier providers assisting us with the delivery of documents related to a situation, or similar
  • third-party service providers assisting us with the operation and interpretation of data obtained through the Google Analytics platform, newsletter management, social network marketing, Adwords (Google Ads), or similar online services
  • potential buyers of the business or parts of our business
  • please note that this list is not exhaustive, and there may be other examples in which we need to share personal data with other parties to provide the services as efficiently as possible or to protect the rights, safety, property of our company or its constituents, employees, suppliers, or others to respond to complaints or to prevent fraud and illegal activities

8. Our use of cookies
Our site may use cookies to analyse our users’ traffic trends and preferences, or to send you remarketing ads.
Please see the Cookie Policy to learn all the information about the cookie we use at the present moment, the purpose of the cookies, how to manage or delete cookie modules and how to pursue your preferences.

9. Third party contractors and other controllers
As mentioned above, we may appoint sub-contractor data processors as required to deliver the Services, such as, without limitation, consulting services of various specialties, document processing and translation, secretarial services, confidential waste disposal, audit, training, IT systems or software providers, IT support service providers, document and information storage providers, cloud providers, marketing and PR agencies, advertising and advertising production, event organization, human resources and payroll companies, security companies and building management bodies, delegates, postal or courier providers assisting us with the delivery of documents related to a situation, or similar, who will process personal data on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place the necessary contractual documentation in relation to any sub-contractor to ensure that they process personal data appropriately and according to our legal and regulatory obligations.
Further, we may appoint external data controllers where necessary to deliver the Services (for example, but without limitation, accountants, attorneys or other third-party experts. When doing so we will comply with our legal and regulatory obligations in relation to the personal data, including but without limitation, putting appropriate safeguards in place.
It is also possible to transfer and share this information, in accordance with the applicable law, to affiliated or partner entities when it is in our legitimate interest to do so.

10. Where do we transfer your data to
To provide the Services or other processing purposes listed here, and in particular if a foreign element is involved, we may need to transfer your personal data to locations outside the European Economic Area. In any case, before transferring personal data to another jurisdiction, we will ensure that an adequacy decision of the level of protection is in force or that the controller or the processor in that jurisdiction offers adequate safeguards or one of the following exceptions apply:

  • you have explicitly expressed your consent to the proposed transfer after you have been informed of the possible risks that such transfers may involve
  • the transfer is necessary for the performance of a contract between you and us or for the implementation of pre-contractual measures adopted at your request
  • the transfer is necessary for the conclusion or for the performance of a contract concluded in your interest between us and another natural or legal person
  • the transfer is necessary for important reasons of public interest
  • the transfer is necessary for the establishment, exercise or defence of legal claims
  • transfer is necessary to protect your vital interests or others when the data subject is physically or legally incapable of giving consent
  • the transfer is made from a register which is intended to provide information to the public and which is open to public consultation

11. How long do we keep your personal data for
We retain the personal data we collect from and about you for as long as it is necessary to fulfil the purpose for which we have collected and to satisfy any legal, accounting, or reporting requirements under our Retention Schedule. In order to determine the appropriate retention period for the personal data we process, we consider the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, legal, accounting, or reporting requirements, and whether we can achieve the scope of processing by other means.
At the expiry date, we may destroy such files without any other notification or liability.

12. Confidentiality and the security of your personal data
We apply appropriate technical, physical and organizational measures that are reasonably designed to protect personal data against unauthorized destruction, loss, alteration, disclosure or access, and against other forms of illegal processing. Access to personal data is limited to authorized recipients based on a need to know basis. We maintain a comprehensive information security program in proportion to the risks associated with the processing. The program is continuously adapted to mitigate operational risks and protect personal data, considering accepted practices in the field. We will also use enhanced security measures when processing any special categories of personal data.
All our partners, employees, consultants, workers, controllers and processors (i.e. those who process your personal data on our behalf for the purposes listed above) who have access to and are associated with the processing of personal data are required to comply with the confidentiality of such personal data, and to guarantee the same level of protection as that provided by the Company.

13. How to access your data and your other rights
You have the following rights in relation to the personal data we hold about you:
a) Your right of access
If you ask us, we’ll confirm whether we’re processing your personal data and, if permitted by the law, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
b) Your right to rectification
If the personal data we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we’ve shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
c) Your right to erasure
You can ask us to delete or remove your personal data in some circumstances such as where we no longer need it. If you are entitled to erasure and if we’ve shared your personal data with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
d) Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances, such as where you contest the accuracy of that personal data or you have objected to the processing. If you are entitled to restriction and if we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.
e) Your right to data portability
You have the right, in certain circumstances, to obtain personal data you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
f) Your right to object
You can ask us to stop processing your personal data, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interests to process your personal data, except if we can demonstrate compelling legal grounds for the processing
  • processing is necessary to carry out a task that is of public interest, unless we can demonstrate compelling legitimate reasons justifying the processing
  • processing your personal data for direct marketing purposes

Vlănţoiu and Associates will never use your personal data to subject you to automated individual decision-making
g) Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.
h) Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal data, you can report it to the relevant Supervisory Authority.
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to professional secrecy obligations or the disclosure involves the personal data of third parties.

14. Changes to this Privacy Policy
We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal data we will update this Privacy Policy from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this Privacy Policy periodically on our website to be informed of how we use your personal data.