xquic Privacy Policy

This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy. 

We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.

Services

This Privacy Policy applies to your use of our Services, whether you are a Member or a Visitor.

This Privacy Policy applies to xquic.com and other xquic-related sites, apps, communications and services (“Services”), including off-site Services, such as our ad services.  For residents of Nevada, California or Designated countries, additional disclosures required by law may be found below. 

Change

Changes to the Privacy Policy apply to your use of our Services after the “effective date.”

Xquic (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account. 

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

1. Data

1.1. Data You Provide To Us

You provide data to create an account with us.  To create an account, you need to provide data including your name, email address and/or mobile number, and a password. If you register for a premium Service, you will need to provide payment (e.g., credit card) and billing information.

1.2. Profile

You have choices about the information on your profile, such as your education, work experience, skills, photo and city or area you are located. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping you find business opportunities.  It’s your choice whether to include personal or sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

You give other data to us, such as by syncing your address book, contacts or calendar.

1.3. Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data or salary), respond to a survey, contact a Seller, or submit a resume, upload a document, or fill out a job application on our Services. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).

If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about events, e.g. times, places, attendees and contacts.

You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

1.4. Data From Others

Others may post or write about you.

1.5. Content and News

You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. Unless you opt-out, we collect public information about you, such as information about your business, professional-related news and accomplishments and make it available as part of our Services (e.g. suggestions for your profile, or notifications to others of mentions in the news).

Others may sync their contacts or calendar with our Services.

1.6. Contact and Calendar Information

We receive personal data (including contact information) about you when others import or sync their contacts or calendar with our Services, associate their contacts with Member profiles, scan and upload business cards, or send messages using our Services (including invites or connection requests). If you or others opt-in to sync email accounts with our Services, we will also collect “email header” information that we can associate with Member profiles.

Customers and partners may provide data to us.

1.7. Partners

We receive personal data (e.g., your job title and work email address) about you when you use the services of our customers and partners, such as employers or prospective employers and applicant tracking systems providing us job application data.

1.8. Related Companies and Other Services

We receive data about you when you use some of the other services provided by us or our affiliates, including Microsoft. For example, you may choose to send us information about your contacts in Microsoft apps and services, such as Outlook, for improved professional networking activities on our Services.

1.9. Service Use

We log your visits and use of our Services, including mobile apps.  We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share articles or apply for jobs. We use log-ins, cookies, device information, and internet protocol (“IP”) addresses to identify you and log your use.

1.10. Cookies and Similar Technologies

We collect data through cookies and similar technologies.  We use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. We also allow some others to use cookies as described in our Cookie Policy. If you are outside the Designated Countries, we also collect (or rely on others who collect) information about your device where you have not engaged with our Services (e.g., ad ID, IP address, operating system and browser information) so we can provide our Members with relevant ads and better understand their effectiveness.  You can opt out from our use of data from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.  

1.11. Your Device and Location

We receive data from your devices and networks, including location data.

When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

1.12. Messages

If you communicate through our Services, we learn about that.

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a xquic connection request, we track whether you have acted on it and will send you reminders. We also use automatic scanning technology on messages to support and protect our site. For example, we use this technology to suggest possible responses to messages and to manage or block content that violates our User Agreement or Business Community Policies from our Services.

1.13.  Workplace Information

When your employer buys a premium Service for you to use, they give us data about you and your eligibility to use the Services that they purchase for use by their workers, students or alumni. For example, we will get contact information for “Company Page” administrators and for authorizing users of our premium Services, such as our recruiting, sales or learning products.

1.14. Sites and Services of Others

We get data when you visit sites that include our ads, cookies or some of our plugins or when you log-in to others’ services with your xquic account.

We receive information about your visits and interaction with services provided by others when you log-in with xquic or visit others’ services that include some of our plugins (such as “Apply with xquic”) or our ads, cookies or similar technologies

1.15. Other

We are improving our Services, which means we get new data and create new ways to use data.

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy.

2. How We Use Your Data

We use your data to provide, support, personalize and develop our Services.

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services (including ads) can be more relevant and useful to you and others.

Our Services allow you to stay in touch and up to date with colleagues, partners, clients, and other professional contacts. To do so, you can “connect” with the professionals who you choose, and who also wish to “connect” with you. Subject to your and their settings, when you connect with other Members, you will be able to search each other’s connections in order to exchange professional opportunities.

We use data about you (such as your profile, profiles you have viewed or data provided through address book uploads or partner integrations) to help others find your profile, suggest connections for you and others (e.g. Members who share your contacts or job experiences) and enable you to invite others to become a Member and connect with you. You can also opt-in to allow us to use your precise location or proximity to others for certain tasks (e.g. to suggest other nearby Members for you to connect with, calculate the commute to a new job, or notify your connections that you are at a professional event).

It is your choice whether to invite someone to our Services, send a connection request, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will include your network and basic profile information (e.g., name, profile photo, job title, region). We will send invitation reminders to the person you invited. You can choose whether or not to share your own list of connections with your connections.

2.1. Stay Informed

Our Services allow you to stay informed about news, events and ideas regarding professional topics you care about, and from professionals you respect. Our Services also allow you to improve your professional skills, or learn new ones. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to personalize our Services for you, such as by recommending or ranking relevant content and conversations on our Services. We also use the data we have about you to suggest skills you could add to your profile and skills that you might need to pursue your next opportunity. So, if you let us know that you are interested in a new skill (e.g., by watching a learning video), we will use this information to personalize content in your feed, suggest that you follow certain members on our site, or suggest related learning content to help you towards that new skill. We use your content, activity and other data, including your name and photo, to provide notices to your network and others. 

2.2. Career

Our Services allow you to explore careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to hire (for a job or a specific task) or be hired by you. We will use your data to recommend jobs or mentees, show you and others relevant professional contacts (e.g., who work at a company, in an industry, function or location or have certain skills and connections). You can signal that you are interested in changing jobs and share information with recruiters. We will use your data to recommend jobs to you and you to recruiters. We may use automated systems to provide content and recommendations to help make our Services more relevant to our Members, Visitors and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.

2.3. Productivity

Our Services allow you to collaborate with colleagues, search for potential clients, customers, partners and others to do business with. Our Services allow you to communicate with other Members and schedule and prepare meetings with them. If your settings allow, we scan messages to provide “bots” or similar tools that facilitate tasks such as scheduling meetings, drafting responses, summarizing messages or recommending next steps. 

2.4 Advertising

We serve you tailored ads both on and off our Services. We offer you choices regarding personalized ads, but you cannot opt-out of seeing other ads.

We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

• Data from advertising technologies on and off our Services, pixels, ad tags, cookies, and device identifiers;
• Member-provided information (e.g., profile, contact information, title and industry);
• Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.), including as described in Section 1.3;
• Information from advertising partners, vendors and publishers; and
• Information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket; using graduation dates to infer age or using first names or pronoun usage to infer gender; using your feed activity to infer your interests; or using device data to recognize you as a Member).

We will show you ads called sponsored content which look similar to non-sponsored content, except that they are labeled as advertising (e.g., as “ad” or “sponsored”). If you take a social action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser. Subject to your settings, if you take a social action on the xquic Services, that action may be mentioned with related ads.

2.5. Ad Choices

We adhere to certain principles for interest-based advertising and participate in industry opt-outs from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self-regulatory tools. You can also opt-out specifically from our uses of certain categories of data to show you more relevant ads. For Visitors, the setting is here.

2.6. Info to Ad Providers

We do not share your personal data with any third-party advertisers or ad networks except for: (i) hashed IDs or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., in a lead generation form) or (iii) data already visible to any users of the Services (e.g., profile). However, if you view or click on an ad on or off our Services, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of mechanisms such as cookies, determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with hashed IDs or device identifiers received from us. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

2.7. Marketing

We promote our Services to you and others.

In addition to advertising our Services, we use Members’ data and content for invitations and communications promoting membership and network growth, engagement and our Services, such as by showing your connections that you have used a feature on our Services.

2.8. Developing Services and Research

We develop our Services and conduct research.  We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.

We seek to create economic opportunity for Members of the global workforce and to help them be more productive and successful. We use the personal data available to us to research social, economic and workplace trends, such as jobs availability and skills needed for these jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

2.9. Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.

2.10. Customer Support

We use data to help you and fix problems.

We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).

2.11. Insights That Do Not Identify You

We use data to generate insights that do not identify you.

We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or create demographic workforce insights.

2.12. Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our Members, Visitors or others.

3. How We Share Information

3.1 Your Profile & Posts, Likes, Follows, Comments & Messages

Any data that you include on your profile and any content you post or social action (e.g., likes, follows, comments, shares) you take on our Services will be seen by others, consistent with your settings. 

Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). Your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of our Services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.

Our Services allow viewing and sharing information including through posts, likes, follows and comments.

• When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Members, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).
• In a group, posts are visible to others in the group. Your membership in groups is public and part of your profile, but you can change visibility in your settings.
• Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
• When you follow a person or organization, you are visible to others and that “page owner” as a follower.
• We let senders know when you act on their message, subject to your settings where applicable.
• Subject to your settings, we let a Member know when you view their profile.
• When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).

Your employer can see how you use Services they provided for your work (e.g. as a recruiter or sales agent) and related information. We will not show them your job searches or personal messages.

3.2. Others’ Services

You may link your account with others’ services so that they can look up your contacts’ profiles, post your shares on such platforms, or enable you to start conversations with your connections on such platforms. Excerpts from your profile will also appear on the services of others.

Subject to your settings, other services may look up your profile. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter or WeChat account to share content from our Services into these other services, or your email provider may give you the option to upload your xquic contacts into its own service. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the link with such accounts.

Subject to your settings, excerpts from your profile will appear on the services of others (e.g., search engine results, mail and calendar applications that show a user limited profile data of the person they are meeting or messaging, social media aggregators, talent and lead managers). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.

3.3. Related Services

We share your data across our different Services and xquic affiliated entities.

We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, we may personalize your feed or job recommendations based on your learning history.

3.4. Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.5. Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of xquic, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand nor do we promise that we will succeed in any legal challenge we mount. 

3.6. Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data will be free from unauthorized access, disclosure, alteration or destruction by any means, including by breach of any of our physical, technical, or managerial safeguards. 

4.1. Cross-Border Data Transfers

We may store and use your data outside your home country.  We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders.  Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.

4.2. Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.  At any time, you can withdraw consent you have provided by going to settings.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the xquic Services you have requested) and “legitimate interests.” 

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.  If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer.

4.3. Direct Marketing 

We currently do not share personal data with third parties for their direct marketing purposes without your permission. 

5. Data Retention

We keep most of your personal data for as long as your account is open.

We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new job every few years, we will retain your information and keep your profile open, unless you close your account. In some cases, we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.

5.1. Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the personal data we have about you.

For personal data that we have about you, you can:

• Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
• Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
• Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

Residents in the Designated Countries and other regions may have additional rights under their laws.

5.2. Account Closure

We keep some of your data even after you close your account.  If you choose to close your xquic account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our Business Community Policies), enforce our User Agreement, or fulfill your request to "unsubscribe" from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Members have copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

6. Contact Information

You can contact us or use other options to resolve any complaints.

If you have questions or complaints regarding this Policy, please first contact xquic online. You can also reach us by physical mail at Xquic, 10907 Valley Forge Circle, King of Prussia, PA 19406.  Residents in the Designated Countries and other regions may also have the right to contact our Data Protection Officer. If this does not resolve your complaint, Residents in the Designated Countries and other regions may have more options under their own laws.

A. CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS

Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights around xquic’s collection, use, and sharing of their personal information.

Xquic does not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your personal information.

Xquic collects various categories of personal information when you use the Service, including identifiers, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information. A more detailed description of the information Xquic collects and how we use it is provided above.  Section 3 describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances.

If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access that information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow xquic to retain and use certain personal information notwithstanding your deletion request. You can learn more about how to submit a data rights request through xquic’s Support Center.  You may also send your request by email to support[at]xquic[dot]com.  We will not discriminate against you for exercising your rights under the CCPA. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.

Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at the address listed above in Section 6.

B. NEVADA RESIDENTS: YOUR NEVADA PRIVACY RIGHTS

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. Xquic does not sell your personal information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us through the Support Center.

C. EUROPEAN RESIDENTS: YOUR PRIVACY RIGHTS AND INTERNATIONAL DATA TRANSFER

If you are a European Resident, you have the right to access your personal data, and the right to request that we correct, update, or delete your personal data. You can object to the processing of your personal information, ask us to restrict processing of your personal information, and request portability of your personal information. Additional information regarding your exercise of these rights is available through the Support Center. Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. The Service generally provides you with a reasonable means to view and change your profile information and you can opt-out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you or in your account settings. If you have any questions or comments about the processing of your personal information, you may contact us as described in Section 6 above. Please note that if you are a European Resident, the “data controller” responsible for protecting your personal data related to the Service is TBD.

For European Residents, please note that the personal information we obtain from or about you may be transferred, processed, and stored outside of the EEA or Switzerland for the purposes described in this Privacy Policy, including in the United States of America. We take the privacy of our users seriously and therefore take steps to safeguard your information, including ensuring an adequate level of data protection in accordance with E.U. standards in effect as of the date of this Privacy Policy. These steps include use of the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection laws. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.