MicroSociety, Inc. – Privacy Statement
Welcome to MicroSociety. Formally, we are MicroSociety, Inc. (“MSI,” “we,” “us,” and “our”), the provider of the MicroSociety services (“MicroSociety” or the “Services”). We provide some of our Services through our website at MicroSociety.org (the “MicroSociety Site”), and through websites hosted on Google and other third-party hosting companies (collectively, “Hosted Sites”), as well as through other forms of communications. The Hosted Sites may be operated and controlled by MSI (“MSI Hosted Sites”) or by a Customer (“Customer Hosted Sites”), as determined by each Customer and MSI from time to time.
We provide our Services to educational institutions (each, a “Customer”) pursuant to license agreements with MSI. Each person or entity authorized by a Customer to use our Services is referred to as a “user” or “you” or “your.” This Privacy Statement applies to MSI Hosted Sites for each Customer and each user. Each Customer Hosted Site is responsible for its own privacy practices and may have posted its own privacy statement.
Users generally fall into several categories:
- Parents and guardians
- Teachers, faculty, staff and administrators working for or with a Customer (“Customer Personnel”)
- Community partners, who are also authorized by a Customer (“Community Members”)
This document is our statement of our privacy practices (“Privacy Statement”). Among other things, it explains how we and some of the companies we work with (each, a “Partner”) collect, use, share and protect the information you provide to us (“your Content” or “User Content”). The User Content may include any personally identifiable information, including without limitation a person’s name, telephone numbers, and electronic mail address, and other information that identifies or is uniquely associated with an individual (collectively, “Personal Data”). This Privacy Statement also discusses your choices about the collection, storage and use of your Personal Data.
Any Content that is not Personal Data is referred to as “Non-Personal Data.” Non-Personal Data may include without limitation information about what Services users review and select, how users respond to Service offerings, how users share information with others, what users say they like and dislike about the Services, all of which we aggregate and anonymize into larger data sets that do not identify individuals (collectively, “Behavioral Data,” which is a type of Non-Personal Data).
Each set of Services is configured by the Customer, with or without the aid of MSI. As a result, the configuration of the Services, as well as the type and amount of Personal Data collected, processed, stored and shared, may change from one Customer to another Customer.
Please note that this Privacy Statement does not apply to any Customer Hosted Sites, nor to any other websites, mobile applications, or businesses. This Privacy Statement does not apply to any Personal Data or other Content collected via any means other than the Services. For each Customer Hosted Site, please review the Customer’s own privacy statement, notices, statements and policies.
By using our Services, you consent to the collection, transfer, analysis, transformation, storage, disclosure and other uses of your Content, including your Personal Data, as described in this Privacy Statement.
- Information We Collect
As noted above, we collect Content from you while providing the Services. Some of the Content is Personal Data that we may use to contact you, and which is necessary to provide the Services. Other Content we collect from you is Behavioral Data and other Non-Personal Data that we aggregate, anonymize, share, and use to improve our Services, the services of our Partners, and others in the industry.
We collect many different types of information from you, both directly and indirectly.
Information you provide us directly
- Registration information. When a Customer or you create or modify an account, or use our Services, the Customer or you may provide Personal Data to us, such as your full name, user name, password, phone number, and email address. For student accounts, we recommend each Customer to anonymize or pseudonymize the student account names and numbers.
- Payment information. We receive the Personal Data of Customer Personnel when we process each Customer’s payments.
- Communications between you and MicroSociety. We may send you emails, and other electronic communications for account verification, notices of changes/updates to features of the Services, technical and security notices, and for other purposes. We may collect and store these communications.
Information we gather from your use of our Services
We collect the following information from your use of our Services.
- Emails. We may save private emails sent to us by users, and we may share your emails with any third parties or other users. Any public posts on Services may be viewed by any user and is public to anyone who visits the Services. You may elect to disclose certain Personal Data and Non-Personal Data. The information you submit in any public forums is not confidential or private, and MicroSociety does not protect it. All information you choose to provide publicly, including information that identifies you or others, can be read, collected, or used by other users, and could be used to send you unsolicited messages and for other purposes.
- User Content. Much of the User Content is shared with other users working with the same Customer or Host Site. Should you include Personal Data in your User Content, other users will see it and may share it, and we and the Customer may see and share it. We also provide users with the ability to communicate with MicroSociety and users on the Services. Such communications may include text, images, and other User Content. As noted in the Terms and our other online documents, we may use and copy the User Content you post. More to the point, your User Content may contain Personal Data about you and other people in the form of names, email addresses, personal health information, and location information. You should also be aware that photographs or drawings of a person, or text descriptions of a person, may be Personal Data to the extent the person may be recognized in and identified by the photograph, drawing or description, and medical or other healthcare information may be gleaned from any medical conditions, disorders or diseases are discussed or portrayed in the User Content, such as dietary restrictions. We may collect and use User Content to market our Services in de-identified form without additional permissions from users; but if we reasonably believe that the User Content includes Personal Data then we will ask for each user’s permission or opt-in prior to marketing the User Content.
- Analytics. We may use third-party analytics tools to help us measure traffic and usage trends and other Non-Personal Data for the Services. These tools collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving our Services. For example, we use analytics tools to understand the sources of user traffic and interaction with the Services, and to understand user traffic on our web pages. We collect and combine this analytics information with analytics information from other users so that it cannot be used to identify any particular individual user. One of the analytics tools we use is Google Analytics. For more information and steps you can take to control Google’s collection and use of your data, please visit Google’s page, “How Google uses data when you use our partners’ sites or apps.” Google also provides an opt-out plugin for web browsers, available here.
- Metadata. Metadata is usually technical data that is associated with other data, including User Content. For example, metadata can describe how, when and by whom an item of User Content was collected and how that User Content is formatted. MicroSociety may collect and store metadata, including about each user’s posts on the Services.
- Links. MicroSociety may keep track of how you interact with links across our Services, including our email notifications and third-party Services by redirecting clicks or through other means. We do this to help improve our Services, to provide more relevant local data, and to be able to share aggregate click statistics such as how many times a particular link was clicked on.
- Device Identifiers. We may access, collect, monitor, store on your device, or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your computer, phone or other device, which uniquely identifies your device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by MicroSociety. A device identifier may deliver information to us or to a third-party partner about how you browse and use the Services and may help us or others provide reports or personalized Content and ads. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.
- Log Data. Our servers automatically record information (“log data”) created by your use of the Services. Log Data may include information such as your Internet Protocol (“IP”) address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. We receive log data when you interact with our Services, for example, when you visit our website, sign into our Services or interact with our email notifications. MicroSociety uses log data to review how we provide our Services and to measure, customize, and improve the Services.
- How We Store Your Information
We currently provide the Services from within the United States, and we store all User Content, including Personal Data, that we currently collect and retain on servers inside the United States. In the future, we may store Personal Data and other User Content on servers located outside the United States, but we are not doing that at this time.
We may have Customers outside the United States that operate Customer Hosted Sites. As noted above, each Customer that operates a Customer Hosted Site is responsible for all privacy practices regarding that Customer Hosted Site. We generally recommend that Customers who operate Customer Hosted Sites store all of their data locally in accordance with local data privacy and security laws and regulations.
Certain types of User Content you submit to us might reveal a user’s full name, phone number, email address, gender, ethnic origin, nationality, age, religion, sexual orientation, or other Personal Data about you or others.
By using our Services, or by submitting your Personal Data to us, you consent to the collection, storage, processing and onward transfer of your Personal Data as stated in the current version of this Privacy Statement.
- How We Use Your Information
We share and use your Personal Data in the following circumstances:
- Opt-in with Your Consent. We may ask for your permission to share your Personal Data with other people and organizations outside of MicroSociety, including to help conduct studies or provide you with other services. As with any opt-in procedure, you are under no duty to agree to a request that you opt-in.
- Partners and Affiliates of MicroSociety. We may share your Personal Data with Partners and with our MicroSociety affiliates (meaning entities controlled by, controlling or under common control with MicroSociety) as necessary to sell and provide the Services. However, any Personal Data stored in one country or jurisdiction would not be forwarded to another country or jurisdiction, except in compliance with applicable laws and regulations.
- Opt-out Email or Postal Address. If you supply us with your postal or email address you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not want to receive such mailings, please let us know by sending an email to us at the “opt-out” address, below. We will remove your name from the list we use internally. Opting-out of these emails does not mean we remove your email from our system entirely, because we still retain your email addresses for other purposes.
- Service Providers. We employ third-party companies and individuals to facilitate our Services (e.g., payment processing, maintenance, analysis, audit, marketing and development). These third parties may have limited access to your Personal Data only to perform these tasks on our behalf and are obligated to MSI not to disclose or use your Personal Data for other purposes.
- Required by Law. We may access, preserve and share your Personal Data in response to a legal request (like a search warrant, court order or subpoena). We may also access, preserve and share Personal Data when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
- National Security and Intelligence Activities. We may release your Personal Data to authorized federal officials for intelligence, counterintelligence and other national security activities when required by law. For example, under current law in the United States, certain federal officials may require that we provide Personal Data and other Content in response to a national security letter, subpoena, demand, or court order. In some cases, we would be required not to tell you that we complied with that letter, subpoena, demand, or court order. Where permitted by applicable law, we reserve the right to comply with, or to fight or quash, any such letter, subpoena, demand, or court order.
- Change of Control. If we sell or otherwise transfer part or the whole of MicroSociety or our assets to another organization (e.g., a merger, acquisition, or reorganization), your Personal Data such as user name and email address, User Content and any other information collected through the Services may be among the items sold or transferred. You will continue to own your User Content, but the license you grant to us in the Terms may be transferred to others at MicroSociety’s sole discretion.
- Non-Personal Data. We may share Non-Personal Data publicly and with publishers, researchers or connected sites. For example, we may share aggregated Non-Personal Data publicly to show trends about the general use of our Services. Non-Personal Data includes aggregated or collective information about multiple users that does not reflect or reference an individually identifiable user.
- Other. In addition to some of the specific uses of information we describe in this Privacy Statement above, we may use Personal Data that we receive to:
- help you efficiently access your information after you sign in.
- remember information so you will not have to re-enter it during your visit or the next time you visit the Services.
- provide personalized Content and information to you and others, which, in the future, could include online ads or other forms of marketing.
- provide, improve, test, and monitor the effectiveness of our Services.
- develop and test new products and features.
- monitor metrics such as total number of visitors, traffic, and demographic patterns.
- diagnose or fix technology problems.
- Your Right to Review, Request Changes, and Disclose Personal Data
Where required by applicable laws and regulations, each user may inspect and receive a copy of their Personal Data as stored in the Services. In rare circumstances, we may deny a request, and we may provide you with an explanation. If we deny your request, you may request a review by another professional, who will be chosen by MicroSociety, and we will comply with the outcome of the review.
Subject to applicable laws and regulations, the Personal Data you provide to us remains completely under your control. If you believe the Personal Data we have is incorrect or incomplete, you may in writing request an amendment to your Personal Data. We will approve or deny each request, and notify you of our decision. If approved, we will amend the Personal Data. We will also make a reasonable effort to notify people to whom the Personal Data was released. In the case of a denial, we will provide the reason for the denial and instructions on how to appeal.
Any information or User Content that you voluntarily disclose for use of the Services, such as your user name, your Personal Data or other User Content, may become available to the public if you release it to other users or to the general public. Once you have shared your Personal Data or your User Content with other people, or otherwise made it public, that Personal Data and your User Content may be re-shared by others.
Most of our users are persons under age 18 (each a “Young Person”), and some users may be younger than age 13. We ask each Customer to obtain appropriate permissions from the parent or guardian of each Young Person, as required or appropriate pursuant to applicable laws and regulations.
If you are the parent or guardian of a Young Person, and you become aware that your Young Person has registered with a Customer or directly with MSI without your express consent, please contact the Customer, or contact us at Legal@MicroSociety.org, and we will work with parent or guardian and with the Customer to either obtain appropriate consents, or to remove the Young Person’s Personal Data and User Content.
MSI will not benefit commercially from any personally identifiable information (“Personal Data”) of students. Customer schools and other educational institutions and their students have the option to input students’ Personal Data into their MicroSociety 2.0 Template, such as names, photos, and email addresses. If Customers input such Personal Data, they acknowledge that MSI may view that Personal Data in the course of providing its services and improving the Template. MSI will use reasonable efforts to obscure or anonymize any such Personal Data we do receive. However, it is the Customer’s sole obligation to protect and avoid sharing student Personal Data.
- Changes to this Privacy Statement
We may modify this Privacy Statement from time to time. We will send you an emailed notice if we have a current email address for you. For any user who has not provided us with an email address, the revised Privacy Statement will become effective no less than ten (10) calendar days after posting on the Services. If you choose not to be subject to a revised version of this Privacy Statement, then you may terminate your account with us.
- Different Locations, Different Laws
The laws and regulations that address privacy rights and responsibilities (collectively, “Laws”) are different from one to another. Indeed, some of the Laws do or do not apply depending on different factors, including:
- Location or residence of the user.
- Location or residence of the individual that is the subject of the Personal Data (“Data Subject”).
- Location of the Customer.
- Location or residence of the person or organization that employs or contracts with the Data Subject.
- Location of each server or other machine where the Personal Data is received, stored, processed or forwarded to, which includes the location of each Hosted Site.
- Location of the relevant office of MSI or any company that processes Personal Data.
Several of the Laws that concern users and MicroSociety are discussed in this Section, but these are not all of the Laws that may apply. In addition, if there is any conflict or ambiguity between the statements made in this Privacy Statement and an applicable Law, then the Law will control.
7.1 United States Federal and State Laws
Several of the federal Laws in the United States may apply to the Personal Data collected by us. Congress has passed several federal information privacy and security laws, while each state in the United States has passed and enforces information privacy and security laws that apply to data subjects, data, and businesses resident in that state.
Currently, all Personal Data of MicroSociety users on the MSI Hosted Site is stored on servers and other machines physically located within the United States.
7.1.1 Children’s Online Privacy Protection Act (“COPPA”)
As noted above, COPPA does apply to the Services. if we learn that any user is a Young Person, and if the Customer or MSI has not received appropriate permissions regarding that Young person, then when the Young Person’s parent or guardian contacts us, we will either obtain the appropriate permissions for that Young Person or close that Young Person’s account and remove all information provided by the Young Person from our Services.
7.2 Your Privacy Rights
This section supplements the information contained elsewhere in our Privacy Statement and applies to all visitors, users, and others (“consumers” or “you”). This notice of privacy rights has been adopted in order to comply with the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this notice. For further information about your rights under California’s privacy laws, please see California’s “Privacy and Data Security” website at https://oag.ca.gov/privacy or any website that supplements or replaces it.
Any reference to privacy rights under California law in this Privacy Statement shall also apply to residents of other states to the extent that other states adopt regulations similar to California’s extensive privacy rights regulations.
You have the right under the CCPA and other privacy and data protection laws, as applicable, to exercise these rights free of charge:
7.2.1 Disclosure of Personal Data We Collect About You
18.104.22.168 You have the right to know:
- The categories of Personal Data we have collected about you;
- The categories of sources from which the Personal Data is collected;
- Our business or commercial purpose for collecting or selling Personal Data;
- The categories of third parties with whom we share Personal Data, if any; and
- The specific pieces of Personal Data we have collected about you.
Please note that we are not required to:
- Retain any Personal Data about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Data; or
- Provide the Personal Data to you more than twice in a 12-month period.
22.214.171.124 Right to Deletion
- Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your Personal Data from our records; and
- Direct any service providers to delete your Personal Data from their records.
- Please note that we may not delete your Personal Data if it is necessary to:
- Complete the transaction for which the Personal Data was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with an existing legal obligation; or
- Otherwise use your Personal Data, internally, in a lawful manner that is compatible with the context in which you provided the information.
126.96.36.199 Protection Against Discrimination
- You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.
188.8.131.52 Why We Collect Your Personal Data
- We use your Personal Data for the following reasons:
- Providing the Services. In order to provide the Services and to comply with legal requirements, we interact with government databases and other platforms which review items of Personal Data.
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
- Debugging to identify and repair errors that impair existing intended functionality;
- Undertaking internal research for technological development and demonstration; and
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
184.108.40.206 Parties With Whom We Share Your Personal Data
- We routinely share Personal Data with:
- service providers we use to help deliver our goods and services to you, such as payment service providers, warehouses and delivery companies; and
- other third parties we use to help us run our business, such as marketing agencies or website hosts.
7.2.2 Rights of Minors
For each student or other user under the age of 18, and a user of any site or Service where this Privacy Statement 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 or letter with a detailed description of the specific content or information to the addresses provided in the section below titled “How to Exercise Your Rights.” 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.
By submitting any Personal Data or other User Content to us, you consent to the storage, processing, use and onward transfer of your Personal Data and User Content to us.
7.2.3 How to Exercise Your Rights
If you would like to exercise any of your rights as described in this Privacy Statement, please do one of the following:
- Complete a data subject request form available on our MicroSociety Site;
- Email us at Legal@MicroSociety.org; or
- Write to us at Attn: Privacy, MicroSociety, Inc., 3401 Market Street, 2d Floor, Philadelphia, PA 19104, USA.
Please note that you may only make a data access or data portability disclosure request twice within a 12-month period.
7.2.4 Verifying Your Identity
If you choose to contact us directly, we may ask you to provide us with information and documentation (e.g., photo identifications) to ensure that you are accessing your own Personal Data and not the Personal Data of someone else.
We are not obligated to make a data access or data portability disclosure if we cannot reasonably verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any Personal Data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
7.3 Your Privacy Rights Outside of the United States
All Personal Data and other data provided by users on each MSI Hosted Site will be stored in the United States under United States law. Accordingly, United States law will apply to all users of MSI Hosted Sites. All users consent to the application of the law of the United States in connection with the Services. Citizens and residents of other countries and regions, such as the European Union, the United Kingdom, and Canada agree that, to the greatest extent possible, that they consent to the application of United States law.
- Outside the United States
If you are located in the European Economic Area (“EEA”), you are regulated by EU data privacy and security laws, including the General Data Protection Regulation (“GDPR”), which applies across the European Union.
If you are located in the United Kingdom (“UK”), you are subject to the UK data privacy and security laws, including the UK Data Protection Regulation, which is similar to the GDPR. For further information on your privacy rights under UK law, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (“ICO”) on individuals’ rights, available at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
If you are located in Canada, you may be subject to Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) or to provincial data privacy laws. For more information on Canada’s data protection laws and regulations, see the website of the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca/en or any website that succeeds it.
As stated in this Privacy Statement, we may share your personal information with our partners in order to deliver the Services. Those third-party recipients are based in the United States.
We generally do not have a data retention policy in place, so we may hold or dispose of all Personal Data until the sooner of our deletion of the Personal Data at our discretion, or you let us know you would like for us to delete your Personal Data.
8.1 Use and Transfer of Your Information to the United States
With the exception of Customer Hosted Sites (which are determined by each Customer and are subject to the privacy statement of each Customer), the Services are operated by MSI in the United States and third parties with whom we might share your personal information as explained above are located in the United States.
If you are located outside of the United States, please be aware that any information you provide will be transferred to the United States. By using or participating in any of the Services or providing your Personal Data or other information to us, you consent to this transfer.
The United States does not have the same data protection laws as Canada, the United Kingdom or the EEA.
While the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal information will be subject to the derogation in Article 49 permitting non-repetitive transfers that concern only a limited number of data subjects, as permitted by Article 49 of the GDPR that is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
If you would like further information, see “How to contact us” below.
8.2 Your Rights
If you want to unsubscribe from receiving emails from MicroSociety you may do so at any time. Each email from MicroSociety includes instructions for unsubscribing from these e-mail communications.
You have a number of important privacy rights. In summary, those include rights to:
- Fair processing of information and transparency over how we use your personal information.
- Access to your Personal Data and to certain other supplementary information that this Privacy Statement is designed to address.
- Require us to correct any mistakes in your Personal Data which we hold.
- Require the erasure of Personal Data concerning you in certain situations.
- Receive the Personal Data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations.
- Object at any time to processing of Personal Data concerning you for direct marketing.
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
- Object in certain other situations to our continued processing of your Personal Data.
- Otherwise restrict our processing of your Personal Data in certain circumstances.
You may also have the right to claim compensation for damages caused by our breach of any data protection laws.
If you would like to exercise any of those rights, please:
- Email, call, or write to us
- Provide us enough information to identify you: account number, user name, registration details, order number
- Provide us proof of your identity and address (a copy of your student ID, driver’s license, passport, or a recent utility or credit card bill)
- Provide us with the information to which your request relates including any account or reference numbers, if you have them
- Use of Email Addresses and Other Contact Information
We collect the email addresses of those who voluntarily provide them to us, including users. You may receive subscription, editorial and other messages from the Services or from us. If you do not want to receive email from us in the future, please let us know at Unsubscribe@MicroSociety.org.
- Contact Us
If you have questions or concerns about this Privacy Statement, please contact us online at Legal@MicroSociety.org, or by postal mail addressed to:
Attn: Privacy, MicroSociety, Inc., 3401 Market Street, 2d Floor, Philadelphia, PA 19104, USA.
- Revision Date and History
This Privacy Statement was last revised: January 7, 2022.
Prior versions of this Privacy Statement are listed below: