Privacy Policy
Claim 4 Misleading Financial Advice and ClaimMFA are trading styles of Claim 4 Misleading Financial Advice Limited is authorised and regulated by the Financial Conduct Authority.
This Privacy Policy sets out how we collect, store and use information about you when you use or interact with our website, www.claim4.claims and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 1st October 2020.
Contents
Summary
Our details
Information we collect when you visit our website
Information we collect when you contact us
Information we collect when you interact with our website
Our use of automated decision-making and profiling
How we collect or obtain information about you from third parties
Disclosure and additional uses of your information
How long we retain your information
How we secure your information
Transfers of your information outside the European Economic Area
Your rights in relation to your information
Your right to object to the processing of your information for certain purposes
Sensitive Personal Information
Changes to our Privacy Policy
Children’s Privacy
Do Not Track Disclosures
Copyright, credit and logo
Summary
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
Data controller: Vaughn Thomas
How we collect or obtain information about you: when you provide it to us (e.g. by contacting us, making an enquiry or signing up to one of our e-newsletters), from your use of our website, using cookies and similar technologies, and from third parties.
Information we collect: name, contact details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name, the services you are interested in.How we use your information: for administrative and business purposes (particularly to contact you), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.
Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.
We would not sell your information to any third parties (other than in the course of a business sale or purchase or similar event).How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled
How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled
How long we retain your information.
How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary and encryption of personal data. In terms of physical security, our network is housed in a secure Datacentre, which has secure locked doors, monitored alarm system, on-site security guard, remotely stored CCTV system, and staff onsite during office hours. Access to our datacentre is via prior appointment only, and all visitors are escorted by members of staff.
Use of cookies and similar technologies: we use cookies and similar information-gathering technologies such as web beacons on our website including essential, functional, analytical and targeting cookies. For more information, please visit our cookies policy here:
https://claim4.claims/cookie-policy
Transfers of your information outside the European Economic Area: we will only transfer your information outside the European Economic Area if we are required to do so by law.Use of automated decision making and profiling: we may use automated decision making and/or profiling
using the Google AdSense, Facebook and Linked In networks. Your rights in relation to your information to access your information and to receive information about its use to have your information corrected and/or completed to have your information deleted to restrict the use of your information to receive your information in a portable format to object to the use of your information to withdraw your consent to the use of your information not to have significant decisions made about you based solely on automated processing of your information, including profiling to complain to a supervisory authoritySensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled
Sensitive Personal Information.
Our details
The data controller in respect of our website is Vaughn Thomas. You can contact the data controller by writing to the above address or sending an email to [email protected] data protection officer for the data controller is Vaughn Thomas. You can contact the data protection officer by writing to the above address or by sending an email to [email protected]
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled
Disclosure and additional uses of your information.
Web server log information –
Our secured servers are located within the UK. Where we have supplied you (or where you have chosen) a password which enables you to access certain parts of our website or Service, you are responsible for keeping the password confidential. We ask you not to share a password with anyone.
Use of website server log information for IT security purposes
We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our and our third party hosting provider’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.
Use of website server log information to analyse website use and improve our website
We use the information collected by our website server logs and third party tools like Google Analytics, Mailchimp etc to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system, browser used, IP address, ISP and pages viewed.
We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.
Legal basis for processing our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.
Cookies
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies on our website, including essential, functional, analytical and targeting cookies and web beacons. For further information on how we use cookies, please see our cookies policy which is available here: www.claim4.claims/cookie-policy
You can reject some or all of the cookies we use on or via our website by changing your browser settings but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit
www.allaboutcookies.org or see our cookies policy
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Storage of your information
The personal information we collect and maintain will be subject to the version of the Privacy Policy in effect at the time of collection. We reserve the right to change this Privacy Policy from time to time and will provide notice of such changes in the Privacy Policy. You should make sure you periodically review the Privacy Policy to make sure it meets your needs.
Contact form
When you contact us using our contact form, we collect name and email contact address. We also collect any other information you provide to us when you complete the contact form, including any optional information, such as phone number and any information you include in the message.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
Legal basis for processing our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Storage of your information
Messages you send us via our contact form will be collected and maintained subject to the version of the Privacy Policy in effect at the time of collection. We reserve the right to change this Privacy Policy from time to time and will provide notice of such changes in the Privacy Policy. You should make sure you periodically review the Privacy Policy to make sure it meets your needs.
Phone
When you contact us by phone, we collect your phone number and any information provided to us during your conversation with us. We do record all phone calls and keep them securely stored for 12 months after our last point of contact with you.
Our use of automated decision-making and profiling
We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.
You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor or IP Vanish.
You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here:
https://claim4.claims/cookie-policy
Profiling
Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Use of profiling for web analytics
Our web analytics service, Google Analytics, collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on) and other interactions with the website. We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy (https://www.ina4.com/cookie-policy). Information collected about you, once collected is anonymised and stored on an aggregate basis.
Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies (see our cookies policy for advice on opting out) and your location will be analysed based on your IP address.
Legal basis for processing: To help us improve our website user experience (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: To help us improve our website user experience
Use of profiling in marketing emails
We use web beacons and 3rd party tools (for example – Mailchimp) in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons and approved 3
rd party tools if you have consented to their use in accordance with our cookies policy (https://www.claim4.claim/cookie-policy)
Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.
Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons) including open rates, click through rates and links interacted with.
How to object: if you wish to amend any of the data which we hold about you, or update your marketing preferences, please contact [email protected]
Legal basis for processing legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content
Disclosure and additional uses of your information
This section sets out the circumstances in which we will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering services from us.
We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
Legal basis for processing legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation). Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc.
Google collects information through our use of Google Analytics
on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised
basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page:
https://www.google.com/policies/privacy/partners/
Legal basis for processing our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by installing the browser plugin here:
https://tools.google.com/dlpage/gaoptout
Transfer and storage of your information
Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled
Transfers of your information outside the European Economic Area.]
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so.
These third parties include our accountants, advisors, affiliates, business partners, independent contractors, and insurers.
Legal basis for processing our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest: running and managing our business efficiently.
We do not display the identities of our business associates publicly by name for security reasons. If you would like further information about the identities of our business associates, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.
Legal basis for processing legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interest(s):sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interest enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interest(s):resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.
Legal basis for processing compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).Legal obligation(s):legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
Legal basis for processing our legitimate interests(Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Retention periods
Server log information: we retain information on our server logs for a maximum of 30 days.
Order information: when you place an order for services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for a further 12 months after which point we will delete your information if you do not take any services from us.
E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation); whether we have any legal basis to continue to process your information (such as your consent);how valuable your information is (both now and in the future);any relevant agreed industry practices on how long information should be retained;the levels of risk, cost and liability involved with us continuing to hold the information; how hard it is to ensure that the information can be kept up to date and accurate; andany relevant surrounding circumstances (such as the nature and status of our relationship with you).
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to
Claim 4 MFA, 1 Commercial Court, Leeds, LS1 6ER or email [email protected] to request access to your information and information related to our use and processing of your information to request the correction or deletion of your information to request that we restrict our use of your information to receive information which you have provided to us in a structured, commonly used and machine-readable format(e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller); to object to the processing of your information for certain purposes(for further information, see the section below entitled
Your right to object to the processing of your information for certain purposes); and to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here:
https://ico.org.uk/global/contact-us/
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here:
http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to-
Letter: Claim 4 MFA Ltd, 1 Commercial Courts, Leeds, LS1 6ER
Email:
[email protected]
Phone: 0113 882 3390
to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and to object to us using or processing your information for direct marketing purposes(including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link or sending an email to [email protected] asking that we stop sending you marketing communications or by including the words “OPT OUT”.
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled
How to accept or reject cookies in our cookies policy, which is available here:
https://www.claim4.claim/cookie-policy
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to [email protected]
Copyright, credit and logo
This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit
https://gdprprivacypolicy.org
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.
Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.
