Data Protection Policy
Last updated: 22.06.2020
We are pleased that you visited our website and thank you for your interest.
In what follows, please find information relating to how your personal data are collected on the web-site www.remonte.com (the “website”/“our website”). We explain which personal data we collect, how and for what pur-poses we process those data, and which rights you have whenever you visit or use individual func-tions of our website. The protection of your personal data is important to us.
Under the EU General Data Protection Regulation (“GDPR”), personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to a natural person. By extension, personal data are not only your personal data such as your name, mailing address, or your email address, but also the technical data arising from or processed in con-nection with the use of the website which data can be attributed to you such as IP address, operating system, or the browser of your end device or your user behavior through so-called cookies.
The controller who, under applicable data protection law, is responsible for the collection and pro-cessing of your personal data whenever you visit and use our website is:
E Mail: firstname.lastname@example.org
Telefon: +49 7462 201200
Telefax: +49 7462 201345
2. Contact information of the data protection officer
You can contact our data protection officer at any time with any questions, inquires, or suggestions you may have regarding data protection matters relating to our website:
Data Protection Officer of Schuh-Union GmbH
E Mail: email@example.com
You can assert your rights as a data subject vis-à-vis our data protection officer. For additional infor-mation, see Section 9 below.
3. Automatic data processing in connection with your visit to our website – purposes and legal bases
It is possible to visit and, for purely informational purposes, to use our website without being re-quired to provide personal data (for instance through registration or the transmission of online forms). However, in order to make our website user-friendly, effective, stable, and secure and in or-der to provide you with additional services, we automatically collect and process (pseudonymized) technical data through interaction with your end device and your browser.
3.1 Automatic data collection and processing by webservers
So that the individual pages of our website can be displayed to you, the following personal data are collected and processed automatically by our webservers, which data are transmitted from your browser:
- uniform resource locator (URL)
- “our agent” identifier containing, depending on your browser, further information
- operating system used
- browser type and version
- referrer URL (last page visited, if transmitted)
- date and time of server inquiry
- IP address
- amount of data transmitted in bytes
The legal basis for processing said data is Article 6(1)(1)(b) GDPR. Processing said data is necessary in order to take steps at your request prior to entering into a contract on the grounds that web-site visits appertain to such steps prior to entering into a contract.
Any technical (pseudonymized) communication data collected and processed that render possi-ble the use of the website (establishing a connection) are stored by our webservers temporarily in protocol files, so-called server log files. Neither a personal analysis of these data nor a consoli-dation with other data sources is effectuated. We use server log files for purposes internal to the system including, but not limited to, technical administration and the ensuring of stability and se-curity of our webservers and website: for instance, in order to identify and to trace, via the IP ad-dress stored, impermissible or abusive attempts to access our webservers. The legal basis for pro-cessing such data is Article 6(1)(1)(f) GDPR, which permits the processing of personal data for purposes of our legitimate interests, provided that such interests are not overridden by your in-terests, fundamental rights, or freedoms. Our legitimate interests are comprised of basic admin-istration and the secure operation of our website.
3.2 Cookies, web analysis tools, and external content
We use the cookies placed by us, as are required for certain functions of the website, on the basis of Article 6(1)(1)(f) GDPR (legitimate interest in providing and optimizing our offer). Cookies and tools of third-party providers as well as cookies and tools for marketing or web analysis purposes are utilized exclusively with your consent on the basis of Article 6(1)(1)(a) GDPR (data subject consent).
You can give your consent regarding any and all cookies and tools by clicking on the appropri-ate button in the cookie banner located at the bottom of our website. Furthermore, on the “Cookie Settings” page, you can give your consent regarding individual categories of cookies and tools by clicking on the slider of the respective category. In the same way, you can with-draw your consent at any time at this page, effective for the future.
Detailed information regarding the data processed by means of cookies and tools utilized can be found on the “Cookie Settings” page of our website. Please click the “show” button for each indi-vidual category.
3.2.1 General information regarding cookies
Cookies are small text files which are stored on your end device and attributed to the browser used by you and by means of which certain information flows to the site that places the cookie. Cookies cannot execute programs, cannot infect your end device with any virus, and cannot cause any other damage to your end device.
Some cookies used by us are deleted after your browser session ends: that is, once you close your browser (so-called session cookies). Session cookies aid in the attribution of various inquir-ies sent by your browser to a common session. These render it possible for your browser to be recognized whenever you use several websites or return to our website, before you close your browser. Other cookies remain on your end device for a specified time period and render it possi-ble that your browser is recognized the next time you visit (so-called persistent cookies). Persis-tent cookies are deleted automatically after a specified period of time, which can vary from cook-ie to cookie.
You can set your browser so that you are informed whenever cookies are placed, and you can decide whether to accept them or to deny them in certain cases or in general. Furthermore, you can set your browser so that all cookies are deleted automatically when you close your browser.Every browser differs in how they manage cookie settings. These settings are described in the help menu of each browser and it is explained how you can change your cookie settings. You can find these for each browser by clicking on the following links:
- Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies
- Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
- Chrome: https://support.google.com/chrome/answer/95647?hl=de&hlrm=en
- Safari: https://support.apple.com/de-de/guide/safari/sfri11471/mac
- Opera: https://help.opera.com/en/latest/web-preferences/#cookies
Please note that the functionality of our website can be impaired if you do not accept cookies.
You can find, on the “Cookie Settings” page, information regarding the purpose of individual cookies, regarding each of the data processed, regarding the providers of cookies and the re-cipients of the data collected, regarding the data protection advisory notices of third-party providers, as well as regarding the storage period of each cookie.
3.2.2 Necessary cookies
We store the cookies displayed under the “Necessary Cookies” section of the “Cookie Settings” page in order to guarantee the secure and uninterrupted operation of the website and in order to be able to offer you certain functions. You will not be able to use certain functions of our website without these cookies.
These cookies are stored by us on the basis of Article 6(1)(1)(f) GDPR, which permits the pro-cessing of personal data for purposes of our “legitimate interests,” provided that such interests are not overridden by your interests, fundamental rights, or freedoms. Our legitimate interests are comprised of the technically compliant and optimized provision of our website.
3.2.3 Marketing, use of Facebook pixel
With your consent, we use marketing cookies so that we can follow your visit to our website and so that we can display content to you which is especially relevant and appealing to you. Infor-mation regarding each cookie stored can be found under the “Marketing Cookies” section of the “Cookie Settings” page.
If you give us your consent, we use marketing services of the social network Facebook to analyze and to optimize our online offerings and our targeted advertising efforts on our website. Such services are provided by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, and – if you are not resident in the European Union – by Facebook Inc., 1601 Willow Road, Menlo Park, CA 94304025, United States of America (“Facebook”). Facebook Inc. has committed to the EU-US Privacy Shield (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
The so-called “Facebook pixel” is incorporated into the website, by means of which visitors of our online offer can be identified as the custom audience to which ads will be shown. Information re-garding the use of our website (for instance, information regarding articles viewed) are collected by said pixel and forwarded to Facebook. Said information can be attributed to your person with the help of further information which Facebook has stored regarding you – for instance, based on your having a Facebook account. With the aid of the information collected through pixel, ad-vertisements of our offers can be blended in and shown to you on your Facebook account based on your interests (retargeting).
In utilizing Facebook pixel, we use the extended match functionality. Here, the data are trans-mitted to Facebook, encrypted, to form custom audiences. Accordingly, we utilize Facebook pixel to display advertisements placed by us only to those Facebook users who have shown an interest in our online offerings or who exhibit certain features (for instance, interests in certain topics or products) which we transmit to Facebook.
What is more, the information collected via pixel can be aggregated by Facebook, and the aggre-gated information can be used by Facebook not only for its own advertising purposes, but also for advertising purposes of third parties. As such, Facebook can, for instance, infer from your surfing behavior on this website certain interests and even use that information to advertise third-party offers. Moreover, Facebook can associate any information collected through pixel with further information about you as collected by Facebook via other websites and/or in con-nection with the use of the social network, such that a profile about you can be stored with Fa-cebook. That profile can be used for purposes of advertising.
More detailed information regarding Facebook and data protection can be found here: https://www.facebook.com/policy.php. More detailed information regarding Facebook pixel can be found here: https://www.facebook.com/business/help/742478679120153?id=1205376682832142. More detailed information regarding the expanded matching function used as part of Facebook pixel can be found here: https://www.facebook.com/business/help/611774685654668.
More detailed information regarding the data that are automatically processed for marketing purposes can be found under the “Marketing Cookies” section of the “Cookie Settings” page. Your personal data are processed within these parameters only if you give us your consent to do so. The legal basis for the use of marketing cookies and of the Facebook pixel is Article 6(1)(1)(a) GDPR, which permits the processing of personal data with the consent of the data subject.
3.2.4 Statistics, utilization of Google Analytics, a web analytics service
We use Google Analytics to be able to analyze regularly and to evaluate the use of our website. With the statistics gained, we can customize our website and the offers thereon to meet market needs better, to be more user-friendly, to be more effective, and to be more interesting and, by extension, to improve and to optimize permanently the website and the offers thereon. Addi-tional information regarding the data processed through Google Analytics can be found under the “Cookies Statistics” section of the “Cookie Settings” page.
Google Analytics is a web analytics service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States of America (“Google”). Google Analytics uses methods, such as cookies, that enable an analysis of how you use the website. Information collected by Google Analytics regarding the use of this website are transferred to and stored on a Google server in the United States. By activating the IP anonymization on this website, your IP address will be trun-cated by Google within the Member States of the European Union or in other contracting parties to the Agreement on the European Economic Area, before that IP address is transmitted to the United States. Only in cases of exception will the full IP address be transmitted to and truncated on a Google server in the United States. On our behalf, Google will use this information to evalu-ate your use of the website, to compile reports on website activity, and to provide to us further services affiliated with the use of the website and of the internet. In this regard, Google is en-gaged as our processer as contemplated by Article 28 GDPR. Google has committed to the EU-US Privacy Shield for those cases of exception in which personal data are transmitted to the United States (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
The IP address transmitted by your browser as part of the Google Analytics service will not be merged with other Google data.
The data shall be processed through Google Analytics only if you give your consent. The legal ba-sis for the use of Google Analytics is Article 6(1)(1)(a) GDPR, which permits the processing of per-sonal data with the consent of the data subject.
After you give your consent, you can end the collection through Google Analytics at any time by withdrawing your consent on the “Cookie Settings” page or by downloading and installing the browser plug-in available through the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
3.2.5 External content and social media
Video platform and social media platform content as well as content of the map service Google Maps are incorporated into our website so that we can make available to you an extended infor-mation and communications offer. Such content and data transmissions to third-party providers are blocked by default and are activated only after you have given, actively, your consent. In the event you would like permanently to activate external media without giving manual consent in each individual case, you can activate the necessary cookies under the “External Media Cookies” section of the “Cookie Settings” page.
When external content is activated, your browser establishes a direct connection to the servers of the respective provider. Through such connection, the provider receives the information that your browser retrieved the relevant page of our online offer, even if you do not have a user ac-count with the provider or are not logged in to that account at that point in time. Webserver log files (including IP addresses) are transmitted by your browser directly to a server of the respec-tive provider and, possibly, stored there. The provider and/or its server can be located outside the European Union or the European Economic Area (for instance, in the United States).
For this reason, any external content incorporated constitute independent services of the re-spective third-party provider. As such, we have no influence over the scope of the data pro-cessed by the third-party provider. Please review the data protection advisory notices of the re-spective third-party provider regarding the purpose and scope of the data processed and used by the third-party provider, on the one hand, and your rights in connection therewith and the settings options designed to protect your privacy, on the other hand.
If you would like the provider of the external content to receive, possibly to store, and/or to re-use data regarding your visit to our website, you should activate external content.
Below please find information regarding the individual external content incorporated into our website. Your personal data are processed within these parameters only if you give your consent. The legal basis for the data processed for the incorporation of external content is Article 6(1)(1)(a) GDPR, which permits the processing of personal data with the consent of the data subject.
Facebook www.facebook.com , is operated by Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, United States of America, und at www.facebook.de by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Information regarding data protection at Facebook can be found at http://www.facebook.com/policy. Facebook Inc. has committed to the EU-US Privacy Shield (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
Instagram is operated by Instagram LLC, 1601 Willow Road, Menlo Park, CA 94025, United States of America. Instagram utilizes standard contractual clauses approved by the European Commission for data transmissions to the United States and, as applicable, other countries and relies on the European Commission’s adequacy decisions about certain countries. Fur-ther information regarding the collection of your data can be found here: https://help.instagram.com/519522125107875?helpref=page_content.
The Google’s map service Google Maps is incorporated into the “Storefinder” page. If you consent to the use of Google Maps and go to a page into which Google Maps has been incor-porated, Google receives the information that you have gone to a page on our website into which such service has been incorporated. Moreover, data are collected which are trans-mitted by your browser to Google. These data are the IP address, date and time of the in-quiry, the amount of respective data transmitted, operating system and its interface, lan-guage and version of the browser.
Such is effectuated independent of whether Google provides a user account into which you were logged or whether no user account exists. If you are logged into Google, your data are attributed directly to your account. If you do not want data to be attributed to your Google profile, you will have to log out from Google before you visit our website. Google stores your data as a usage profile and uses these for purposes of advertising, of market research, and/or of website customization to meet market needs. If you want to exercise your rights such as your right to object to the creation of such user profile, you must do so vis-à-vis Google.
Vimeo is an online video portal of Vimeo Inc., 555 West 18th Street, New York, NY 10011, United States of America (“Vimeo”).
When you watch a Vimeo video, a connection to Vimeo’s servers is established. Once estab-lished, the Vimeo server is notified of which of our pages you visited. Moreover, Vimeo re-ceives your IP address. Such is also true if you have not logged into Vimeo or if you have no Vimeo account. The information collected by Vimeo is transmitted to Vimeo servers located in the United States. Vimeo has committed to the Privacy Shield Framework (https://www.privacyshield.gov/participant?id=a2zt00000008V77AAE&status=Active).
Whenever you are logged into your Vimeo account, you make it possible for Vimeo to attrib-ute your surfing behavior directly to your personal profile. You can prevent this from happen-ing by logging out of your Vimeo account before you visit our website.
YouTube is an online video portal of YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States of America (“YouTube”). YouTube LLC is a subsidiary of Google.
Whenever you watch a YouTube video, your browser automatically causes, through the rele-vant YouTube components, the download, from YouTube, of a representation of the relevant YouTube components. As part of this technical process, YouTube and Google receive knowledge of which specific sub-page of our website has been visited by you. Insofar as you are, at the same time, logged into YouTube, said information will be attributed to the respec-tive YouTube account affiliated with your person.
If you are logged into YouTube at the time you visit our website, then YouTube and Google re-ceive, through the YouTube components, information that, and always at the point in time at which, you have visited our website; such occurs independently of whether or not you have clicked on a YouTube video. If you do not want your data to be attributed to your YouTube profile, you must log out before you visit our website.
4. Collection and processing data provided by you – purposes and legal bases
The use of certain functions of our website requires that personal data be collected and processed. We process those data on our website only if you yourself have provided them to us and such is permitted by law.
In the event that your consent is necessary for the collection and processing of data over and beyond the above, we will ask you at the appropriate juncture of our website to give us your consent. This consent will be logged by us. You have the right to withdraw your consent, after you have given it, at any time, in whole in or in part, effective for the future. Any such withdrawal shall be logged by us.
4.1. Contact form
Under “Contact,” we provide a contact form that you can use to send us your any questions, in-quires, and suggestions.
In order to process and to respond to your request, we will need not only your inquiry, complete with subject line, but also your email address to which we can send our response. The legal basis for the processing of said data is Article 6(1)(1)(b) GDPR. The processing of such data is necessary in order to take steps at your request prior to entering into a contract on the grounds that con-tact inquiries appertain to such steps.
Extending beyond the foregoing, you can voluntarily provide your name in order to facilitate our making contact with you. In the event you provide your first and/or additional names, we will use that data exclusively to contact and to address you personally. The legal basis therefor is Arti-cle 6(1)(1)(f) GDPR, which permits the processing of personal data whenever there exists a legiti-mate interest, provided that such interests are not overridden by your interests, fundamental rights, or freedoms. Our legitimate interests consist in our ability to address you personally in re-sponse to your inquiry with which contact to us was made. If you are opposed thereto, then please refrain from filling out the fields “first name” and “last name.”
We use the data provided by you only to process your request. These data are not used for any other purpose; nor are they merged with other data or shared with third parties.
On our “Storefinder” page, we provide to you a tool with which you can find points of sale for our products in your area. For this purpose, we collect and process, with your agreement, your location data so that we can identify and show to you where the nearest point of sale is located. Providing your location data is voluntary. If you do not provide your location, all points of sale for our products will be shown on our “Storefinder” page without any further restrictions applied.
With your agreement, your location data are transmitted automatically via your browser’s geolo-cation function whenever you go to the “Storefinder” page. For this purpose, a window will open with which you can give your consent to the transmission of your location data. If you give your consent, the IP address, transmitted by your browser, and available information regarding access nodes in your area will be used to identify your approximate location. Alternatively, you can enter your location manually in the “Your location” field. If you transmit your location data via your browser or manually, we will use those data only to identify the nearest point of sale and will not store those data beyond the specific process relating to your inquiry.
If you have given your consent to use Google Maps (see Section 3.2.5 above), your location data will be transmitted to Google as the maps service provider and be recorded there as coordinates in order to show your location and the nearest point of sale. Please note that, in using Google Maps, further data will be collected and that we have no influence on the conjunction and addi-tional processing of those data by Google. Further information regarding how the data is used and processed by Google Maps is available in Section 3.2.5 above.
The legal basis for the processing of location data within the parameters of the “Storefinder” page is Article 6(1)(1)(a) GDPR, which permits the processing of personal data with the consent of the data subject.
5. Recipients of personal data
The personal data collected by us during your visit and purely informational use of our website (see Section 3 above) and the personal data, too, collected while certain functions and offers of our web-site are being used (see Section 4 above) are, as a matter of principle, not shared with other recipi-ents or otherwise transmitted, unless such is stated expressly in this Data Protection Policy. The ex-ception is mandatory transmissions of personal data to government bodies and authorities as well as to private rights holders based on statutory provisions or court and/or regulatory decisions as well as, in the case of attacks on our rights, the sharing of said data with government bodies and authori-ties for the purposes of enforcing our rights and pursuing criminal prosecution.
However, in operating our website and rendering and processing individual website functions and offers, we do use, in part, outside technical and other service providers who support us in the render-ing of our services and who have been selected with due care. To the extent necessary, these service providers, engaged by us, process your personal data on our behalf, each pursuant to instructions for the purposes specified in these data protection advisory notices. They are required by contract to adhere strictly to this Data Protection Policy; applicable data protection law, rules, and regulations; and our instructions (so-called processors as contemplated by Article 28 GDPR). The same applies to any subcontractors to the extent that our processors engage subcontractors with our prior consent.
As part of its website hosting and troubleshooting efforts, maxcluster GmbH, Technologiepark 8, 33100 Paderborn, Germany, processes on our behalf the data collected in carrying out those efforts (see Section 3.1.). Furthermore, processors are engaged by us to conduct web analyses (see Section 3.2).
6. Processing personal data in “third countries”
We process the personal data collected on the website within the Member States of the European Union. Personal data are transmitted to other “third countries” – that is, countries outside the Euro-pean Union and the European Economic Area – only if we give you express notice thereof.
Some of the processing set forth in Section 3.2 above encompass data transmissions to the servers of third-party providers contracted by us and located in the United States of America. Data are trans-mitted on the basis of the standard contractual clauses of the European Commission (compare https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF) as well as in accordance with the principles of the EU-US Privacy Shield (https://www.privacyshield.gov/welcome).
7. Data security
The personal data collected and stored by us are held in confidence and protected by suitable tech-nical and organizational precautions from loss, modifications, and unauthorized access by third par-ties.
This website uses SSL or TLS encryption to protect the transmission of personal data and other confi-dential content.
8. Duration of storage
In general, we store personal data only for as long as they are necessary in relation to the purpose for which the respective data are processed or until such time as you assert, based on legitimate grounds, your right to obtain the erasure of your personal data (see Article 17(1) GDPR). After the storage periods lapse and/or in response to your legitimate assertion of your right to erasure, we review in each case whether certain personal data are still needed for (other) legitimate purposes and, if not, whether contractual or statutory retention periods stand in opposition to an erasure of the personal data. In these cases, the personal data so affected will continue to be stored for as long as they are needed in relation to the purpose of such (other) legitimate purpose and/or for the dura-tion of any contractual or statutory retention periods relating to those purposes. For other purposes, however, they are blocked and then erased permanently after the respective contractual or statutory retention period has lapsed.
The technical communication data contained in the server log files (see Section 3.1 above) are erased by no later than seven days of the date on which they were collected.
The session cookies placed by us are deleted once you close your browser. Persistent cookies used by us remain stored on your end devices until such time as their preprogrammed life span has expired or until such time as you remove them manually (see Section 3.2.1 above). The storage period of indi-vidual cookies can be viewed at the “Cookies Settings” page. The data collected through Google Ana-lytics are erased and the IP address anonymized (see Section 3.2.4 above). Through an agreement with Google, we have limited the storage period of the data collected through Google Analytics to a maximum of fourteen (14) months. The storage period of data transmitted to third-party providers can be reviewed in the privacy policies of the third-party providers (see Sections 3.2.3 and 3.2.5 above).
The data collected through the contact form (see Section 4.1 above) are stored by us only for as long as they are needed to process your inquiry and to respond to any questions in connection therewith. The data are erased, in cycles, by no later than six (6) months of the date on which you most recently sought us out and actively contacted us.
Extending beyond the foregoing, it can be necessary to store data on accounting or other statutory grounds for a time period equal to storage periods prescribed by applicable law.
The location data collected via the “Storefinder” page are not stored by us and are erased directly after your inquiry has been processed.
9. Your rights
Provided that the statutory conditions contemplated by Article 15 et seqq. GDPR are met, you have the following rights regarding your personal data stored by us:
- You can obtain from us at any time information whether personal data and which categories of personal data concerning you are stored by us and for which purposes they are processed and, where applicable, which recipients or categories of recipients receive that data. Fur-thermore, you can request access to the information relating to your personal data as listed in Article 15 GDPR (right of access).
- Subject to statutory conditions, you also have the right to rectification (Article 16 GDPR), a right to erasure (Article 17 GDPR), and a right to restriction of processing (blocking) (Article 18 GDPR) of your personal data.
- Under Article 20 GDPR, you also have the right to receive from us the personal data concern-ing you, which you have provided, in a structured, commonly used, and machine-readable format; you can also transmit or cause the transmission of those personal data to another controller (right to data portability).
- You also have the right to withdraw your consent at any time after you have given it.
Extending beyond the foregoing, you have the right to object to the processing of data in cases involving data processed on the basis of any legitimate interests of the controller or of any third party (see Sections 3.1, 3.2, 4.1 above) whenever the statutory conditions con-templated by Article 21 GDPR have been met.
To assert your rights as a data subject, you can contact us at any time by sending an email to firstname.lastname@example.org or by sending us a message to the address specified under Section 1 above.
Under Article 77(1) GDPR, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
10. Change in the Data Protection Policy
We can modify this Data Protection Policy at any time to reflect changes in factual or legal circum-stances and shall publish each most recent version of this Data Protection Policy here. You can see when this Data Protection Policy was last amended by reviewing the date provided (“Last updated”) first set forth at the head of this Data Protection Policy.