Privacy policy and cookie policy

Privacy policy and cookie policy of the website https://sare.pl/ (referred to in the text as the Website)

The Privacy Policy describes the rules of Processing and protection Personal Data of the Users as well as other entities using the Website. This document also describes the rules of usage of cookie files. The Privacy Policy of the Website document is an informative document.

Contents list:

1. Definitions
2. Personal Data Controller
3. Document target group
4. Contact form – information obligation
5. Account – information obligation
6. Newsletter, Commercial Information – information obligation
7. The blog and the comments system – information obligation
8. Social media – information obligation
9. Recipients of Personal Data – information obligation
10. Rights of concerned persons
11. Profiling and transfer of Data to third countries and international organisations
12. Technical information and surveillance technologies
13. Cookie policy
14. Changes to the Privacy Policy

1. Definitions

1) Personal Data (Data) – denotes all kinds of data about an identified or identifiable natural person (‘Concerned Person’); an identifiable natural person is any person who may be directly or indirectly identified, in particular on the basis of identifiers such as the first and last name, identification number, location data, on-line identifier or any particular detailed describing the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person.

2) Registration form – an interactive form available on the Website, e. g. allowing the establishment of a Customer Account.

3) Commercial Information – any piece of information directly or indirectly meant to promote goods, services or the image of an entrepreneur or a person performing a profession, whereby their right to operate within that profession is determined on the fulfilment of requirements set forth in separate acts of law, excluding information allowing communication by electronic means with a specific person, and any information about goods and services that is not used to achieve a trade or commercial effect required by the entity contracting its distribution, in particular without remuneration or any other advantages from producers, retailers and service providers.

4) Customer
a) a natural person possessing full capacity to perform legal activities, and in cases foreseen by commonly applicable provisions of the law, also a natural person possessing limited capacity to perform legal activities,
b) a legal person,
c) an organisational entity without legal personality, by law provided with legal capacity, who had concluded or is looking to conclude a contract of sale with the Service provider, and one who uses
or is looking to use an Electronic Service.

5) Customer Account (Account) – An electronic service described by an individual name (login) and password provided by the Customer, a collection of Data within the IT system of the Service Provider, where Customer-provided Data is collected, including communication and address data and an order history.

6) Business Partner
d) a natural person possessing full capacity to perform legal activities, and in cases foreseen by commonly applicable provisions of the law, also a natural person possessing limited capacity to perform legal activities,
b) a legal person,
c) an organisational entity without legal personality, by law provided with legal capacity, who uses the services and products offered by the Controller, but also a supplier, subcontractor,
6) Newsletter – An Electronic Service, provided by the Service Provider by way of electronic mail, which allows all persons using it to subscribe to and automatically receive by electronic means regular, cost-free information e. g. about new products, special offers, including Commercial Information.

7) Contacting Person: Any person making contact with the Controller by phone or text message, by e-mail, by the contact form available within the scope of the specific Website, via other communication resources, by traditional post.

8) Supervisory Body – The Chairman of the Polish Data Protection Office.

9) Processing – an operation or a set of operations performed on Personal Data or sets of Personal Data in an automated or non-automated manner, such as collection, saving, organising, ordering, storage, adaptation or modification, downloading, browsing, usage, disclosure by transmission, distribution or any other form of provision, adaptation or fusion, limitation, deletion or destruction.

10) GDPR: Regulation (EU) 2016/ 679 of the European Parliament and of the Council of April 27th, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/ 46/ EC (General Data Protection Regulation) of April 27th, 2016 (OJEU L no. 119, page 1).

11) Website – The website, to which this Privacy Policy applies.

12) Electronic Service – A service provided by electronic means by the Service Provider for the Customer via
the Website.

13) Service Provider – The Data Controller indicated in chapter 2.

14) User – Any person using the Website, including: A Customer, a Contacting Person.

2. Personal Data Controller

The Personal Data Controller, in the meaning used by the Regulation (EU) 2016/ 679 of the European Parliament and of the Council of April 27th, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/ 46/ EC (General Data Protection Regulation) of April 27th, 2016 (OJEU L no. 119, p. 1), referred to in the text as the GDPR, is the company Digitree Group S.A., with seat in Rybnik, Poland, address Raciborska 35a, 44-20 Rybnik, NIP (tax id.) no.: 642-28-84-378, KRS (court reg.) no.: 0000369700, REGON (stat.) no.: 240018741, referred to in the text as the Controller, being at the same time the Service Provider of the Website.

The Controller had appointed a personal data protection inspector, who can be contacted by e-mail under iod@digitree.pl, or by traditional post at the address Digitree Group S. A., Raciborska 35a, 44-200 Rybnik, Poland.

3. Document target group

The Privacy Policy is targeted at Users and other entities using the Website, if:
1) You visit the Website or make use of it, including Your usage of services (including electronic services provided within the scope of the Website), such as the possibility of establishing of an account, signing up for the Newsletter/ receiving Commercial Information, the possibility of commenting on the blog, the possibility of sending messages to the Controller using the electronic contact form and other options of the website, including those described in the Website regulations provided by the Controller, or if You use the profiles of the Controller in social media (Facebook, LinkedIn, Twitter, YouTube, Instagram),

2) You are the User (or a Customer) making use of services and products offered by the Controller, or a Business Partner of the Controller,

3) You are representatives of a Business Partner, a natural person acting in name of a Business Partner or a contact person of a Business Partner, including in particular their employee or co-worker.

4) You are contacting us by phone or text message, by e-mail, using a contact form that’s available as part of the Website or using other means of electronic communication, by regular post, or the Controller is contacting you using one of the methods indicated above.

4. Contact form – information obligation

1) Within the scope of the Website, the Controller may collect Personal Data of the Users contacting the Controller, whereby this Personal Data is necessary to implement the specific relevant pleace of the User and to contact them for the purpose of replying.

2) The legal basis for the Processing of the Personal Data in relation to contact with the Controller, as well as after any conclusion of the contact, shall be a justified objective in the form of e. g. execution of communication and then for the purpose of archiving it to be able to show the course of communication in the future, as well as in case of necessity to establish, assert or defend claims (in line with art. 6 section 1 letter f of the GDPR), if contact would lead to the conclusion of a contract, the Data shall be processed on the basis of art. 6 section 1 letter b of the GDPR.

3) The content of correspondence may be archived. If it would be archived, it will be stored until the expiry of the statute of limitations, which may potentially arise in relation to the conducted correspondence. The statute of limitations is six years, and for claims concerning periodic services and claims related to the operation of a business – three years. However, the expiry of the statute of limitations falls on the last day of the calendar year, unless the statute of limitations is shorter than two years.

4) The Provision of the Data is voluntary yet necessary to contact us. The result of any failure to provide the Data will be the inability to communicate with You.

5. Account – information obligation

1) Within the scope of the Website, the Controller may collect User Personal Data that are necessary to provide full services to the User, including the establishment and management of the Account(s) of Users, the solution of technical difficulties related to the Account and the provision of relevant functions concerning the Account (e. g. when registering within the SARE System).

2) The legal basis for the Processing of the Personal Data shall be the execution of the contract or activities preceding it (in line with art. 6 section 1 letter b of the GDPR) and a justified objective in the form of e. g. execution of communication and then for the purpose of archiving it to be able to show the course of communication in the future, as well as in case of necessity to establish, assert or defend claims (in line with art. 6 section 1 letter g of the GDPR).

3) Data related to the Account shall be stored until the time of removal of the Account, or until the expiry of the statute of limitations for claims that may potentially arise in relation to the operation of the Account. The statute of limitations is six years, and for claims concerning periodic services and claims related to the operation of a business – three years. However, the expiry of the statute of limitations falls on the last day of the calendar year, unless the statute of limitations is shorter than two years.

4) The provision of Data as indicated in detail during the registration process is necessary to open the Account. Failure to provide the Data shall preclude the opening of the Account. The Data indicated as optional during the registration process may also additionally be provided.

6. Newsletter, Commercial Information – information obligation

1) Within the scope of the Website, the Controller may collect Personal Data of Users for the purpose of sending out the Newsletter and Commercial Information on the basis of the expressed consent, pursuant to art. 6 section 1 letter a of the GDPR, and according to legally justified interests pursuant to art. 6 section 1 letter f of the GDPR, which, in this case, is sending the Newsletter and Commercial Information as well as defence against any complaints that may emerge in connection to the sending of the mail messages. With respect to the information that might also constitute Personal Data, and which does not originate directly from You but was collected automatically by the Newsletter mailing system or the system to send out marketing information and Commercial Information (e. g. IP number, location), we Process Your Personal Data on the basis of a legally justified interest (pursuant to art. 6 section1 letter f of the GDPR), which is
working towards the improvement of our activities and showing, if necessary, which link from the Newsletter, the marketing information or Commercial Information was clicked by You. If the basis of the Processing is Your consent to receiving the Commercial Information or the Newsletter, You may withdraw it at any time by Your submission sent by e-mail or using the link provided in every mail message we sent.

2) If the Processing is based on legally justified interests, then the Personal Data will be Processed until the time of effective complaint, e. g. by Your submission made via e-mail or by clicking on a link provided in every mail message we sent.

3) The Personal Data will be Processed:
a) if the basis is formed by a consent: Until the consent is withdrawn.
b) if the basis is a legally justified interest: until the time of effective submission of a complaint or until the achievement of the objective of the Processing, e. g. until the expiry of the statute of limitations of claims that might potentially arise in connection to the operation of Your Account. The statute of limitations is six years, and for claims concerning periodic services and claims related to the operation of a business – three years. However, the expiry of the statute of limitations falls on the last day of the calendar year, unless the statute of limitations is shorter than two years.

4) The Provision of the Data is voluntary, however, it is necessary in order to receive the Commercial Information/ Newsletter.

7. The blog and the comments system – information obligation

1) Data provided when adding a comment are used for the purpose of publication of a comment on the blog, and the legal basis for the Processing of this data is the consent (art. 6 section 1 letter a of the GDPR) stemming from the addition of the comment.

2) Data will be Processed of the the period of operation of comments on the blog. One may motion to the Controller to have the comment removed, by an inquiry sent to the e-mail address given in the Website footer. The removal of the comment will equal the removal of Data from the Website.

3) The provision of the Data is voluntary yet necessary to add a comment.

8. Social media – information obligation

1) When You watch our profiles and accounts on social media such as Facebook, LinkedIn, Youtube, Twitter, Instagram, or when You interact with our profiles and accounts (e. g. You post a comment, share or like a post), we can view Your Data provided in the said social media. Your Data will be Processed on the basis of legally justified interests (art. 6 section 1 letter f of the GDPR) in order to manage our social media presences, conduct correspondence with You, analyse statistical data, create groups of recipients when configuring advertisements, e. g. on Facebook, to promote our band and improve the quality of our services, and if necessary – to assert claims and defend ourselves against claims.

2) Your Personal Data processed for the above-indicated purposes will be processed exclusively within the scope of our usage of our profile/ account on the given platform, and with respect to other modes of use of the social media by You, Your Personal Data will be processed by the owner of the relevant site (e. g. in case of Facebook and Instagram this is Meta Platforms Ireland Limited: https://pl-pl.facebook.com/privacy/explanation; in case of LinkedIn this is LinkedIn Ireland Unlimited Company: https://pl.linkedin.com/legal/privacy-policy; in case of Youtube this is Google LLC: https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/) on the basis of the relevant regulations and privacy statements.

3) The Controller will process the above-indicated Personal Data until the time of effective submission of a complaint or until the achievement of the purpose of Processing.

4) The Provision of the Personal Data is voluntary, yet necessary in order for You to watch and interact with our profiles and accounts.

5) In case of our Facebook profile we indicate that we are co-controllers of Your Persoinal Data as users of the Website or Facebook group together with Meta Platforms Ireland Limited (pursuant to the resolution of the CJEU, the Court of Justice of the European Union, the creator of a Facebook page is co-controller of the Personal Data together with Meta Platforms Ireland Limited). We hence recommend that You also acquaint yourselves with the Facebook Privacy Policy: https://pl-pl.facebook.com/privacy/explanation.

9. Recipients of Personal Data – information obligation

The Controller hereby informs the Users of the Website that the recipients of Your Personal Data are:
1) the internet domain supplier,
2) the hosting provider, who stores the Personal Data on the server, where the Website is installed,
3) providers of cloud computing services, where files are stored, where Your Personal Data may be kept,
4) entities providing tools used to analyse Website activity,
5) the entity providing services concerning technical and IT management of the Website,
6) other providers of services related to the operation of the Website, if the need would arise to provide them with access to Your Personal Data. Your Personal Data may also be transferred to other entities, should such an obligation stem from commonly valid provisions of the law or binding decisions/ orders of courts of law, such as e. g. to courts, prosecutor offices, tax offices.

10. Rights of concerned persons

You have the following rights:

1) right to access the Personal Data (e. g. You may receive from the Controller a confirmation as to whether Your Personal Data is being Processed by us or not; if so, You have the right to request access to them and to obtain information related to their processing, for instance, the objective of Processing, the recipients or categories of recipients of Personal Data, the planned period of storage of the Data or the criteria of determination of this period, etc., as well as to acquire a copy of the Data),

2) right to correct the Data (e. g. amend it, correct it, update it),

3) right to complain against the Processing of Your Personal Data (if the Controller Processes Your personal Data, if this Processing is necessary for the purposes stemming from legally justified interests of the Administrator, then at any time, for reasons related to Your specific situation, You have the right to complain against the Processing of Your Personal Data, to which the complaint would apply, including profiling; in such a situation, the Controller will cease the Processing of Your Personal Data, unless they would be able to show legally justified grounds for the Processing that would supersede Your interests, rights and freedoms, or if the Processing of this Data would be necessary for the purpose of establishment, assertion of or defence against legal claims; in addition, You are entitled to submit, at any time, a complaint against the Processing of Your Personal Data for the purposes of direct marketing, if it would profiling within the scope
related to such direct marketing).

4) right to have the Processing of Your Personal Data limited (this is possible in each of the following cases: You question the correctness of Your Personal Data; the Processing is unlawful, and You demand a reduction of the scope of Processing instead of the removal of Data; the Controller does not need Your Personal Data any more, but You need them to make use of defence or legal claims or You oppose the processing of Personal Data, and the Controller shall verify the justifiability of Your complaint),

5) right to transfer Your Personal Data (if the Processing is taking place on the basis of a consent or on the basis of a contract, and if the processing of the Personal Data is being conducted automatically then You are entitled to receive the Personal Data that You provided to the Controller in a structured, commonly used machine-readable format, and You are entitled to send this Personal Data to any other Controller so long as this is technically possible),

6) right to have the Data removed (however, only in situations described by the provisions of the GDPR, e. g. if Your Personal Data is not necessary for purposes, for which they were collected, or Processed in any other way, or if they were Processed unlawfully),

7) right to withdraw consent (the Consent may be withdrawn at any time, without influence on the legality of Processing that was performed on the basis of the consent before it was withdrawn),

8) right to complain to a supervisory authority (the Chairman of the Polish Data Protection Office, at the address: Polish Data Protection Office, Stawki 2, 00-193 Warsaw, Poland, e-mail: iod@uodo.gov.pl).

11. Profiling and transfer of Data to third countries and international organisations

1) The Controller may use profiling on the Website, for the purpose of direct marketing, however, decisions made on the basis of such profiling by the Controller do not concern the conclusion or the decline to conclude a contract of sale or the possibility of using electronic services. The Controller does not any automatic decision making mechanism, including profiling, with respect to the Data.

2) The result of profiling may be e. g. provision of a reduction to a User, sending of a rebate code, reminders concerning Controller services, sending of suggestions of service purchases that might e. g. correspond to the interests of that person. In the end, however, it is the User who freely decides on whether they would e.g. like to make use of the rebate they got, or to conclude a contract with us. The profiling on the Website may entail an automatic analysis or a prognosis of behaviour of a user of the Website, e. g. in terms of viewing of a specific subpage on our website. A condition of such profiling is the Controller holding the Personal Data of such a User, in order to e. g. provide them with a rebate code e. g. by e-mail.

3) The Concerned Person has the right to be exempt from decisions based exclusively on automatic Processing, including profiling, which would cause legal effects for this person or significantly affect them in a similar manner (right to complain).

4) The Data will not be transferred to third countries or international organisations.

12. Technical information and surveillance technologies

1) The Controller acquires information about Users e. g. by collecting server logs using the hosting provider.

2) Data stored in the server logs is not linked to specific persons using the Website and is not used for the purpose of identification of persons using the Website.

3) Server logs constitute exclusively auxiliary material used to manage the Website, and their content is not disclosed to anyone but persons authorised to manage the server.

4) The Controller reserves the right to filter and block messages sent by the internal messaging system, in particular if they would constitute spam, contain banned content or in any way endanger the safety of the Website Users.

5) The Controller registers data transferred to the server by web browsers or User devices automatically, e.g. IP addresses, software and hardware parameters, the pages being viewed, the identification number of the mobile device and other data concerning the equipment and usage of the systems. The collection of this data will take place during use of the Website.

6) The Controller informs that they may use the following technologies surveilling the actions of the user/User within the scope of the Website:
a) Google Analitycs Tracking Code – used for the purpose of analyses of Website statistics and to operate the Google Ads tool; information concerning Google Analytics may be found at:
https://support.google.com/analytics/answer/6004245,

b) Facebook conversion pixel (JavaScript code piece) – used to monitor events on the Website and to manage Facebook ads; the information Processed within the scope of the Facebook pixel are anonymous – they do not allow the Controller to identify a specific person. More information related to Facebook’s use of the Data collected by the pixel can be found here: https://www.facebook.com/privacy/explanation,

c) LinkedIn pixel – used to conduct advanced analytics via the LinkedIn Recruiter, concerning who is watching and reacting to activities on a company’s LinkedIn page. All data is encrypted. The LinkedIn browser cookie file is stored in the User’s web browser until the User deletes the cookie file or until the cookie file expires (with gradual removal from the time of last loading of the conversion pixel by the user’s web browser). Users may block or remove the cookie files at any time. More information related to LinkedIn’s usage of the Data collected by the pixel can be found here: https://www.linkedin.com/help/linkedin/answer/a412139,

d) Hotjar analysis tool – supplied by Hotjar Limited, address: Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, with seat at Malta – used for analysing website behaviour, e. g. the time spent on the individual pages, the buttons that the User clicks, the links the User uses, everything for the purpose of optimising the page to fit the User experience,

e) the Revhunter tool – provided by the company Inis Sp. z o. o., address Raciborska 35a, 44-200 Rybnik, Poland – used for the purpose of presenting in User e-mails advertisements that are adapted to their preferences, to create offers and recommendations on the basis of the User’s on-line activity; the reception of personalised advertisements/ offers is conditioned on signing up to our Newsletter,

f) the tool provided by the company Sales Intelligence Sp. z o. o., address Jodłowa 1/ 3, 81-526 Gdynia, Poland – following the Website User for the purpose of registration of the actions that they undertake within the scope of the Website, to be used to present in user e-mails advertisements adapted to their preferences, to draw up offers and recommendations on the basis of User activity at the Website; the reception of personalised offers/ advertisements is conditioned upon signing up to our Newsletter beforehand, and then the e-mail address is linked to the User using this tool’s cookies,

g) the SAREpush tool (proprietary) – used to send web push notifications, short messages sent to users who consented to receiving them; these messages include an icon, large image, text; the use of the notifications is completely voluntary; the User may object to receiving them at any time, using the web browser’s settings,

h) the LiveCall tool – provided by the company Livecall Software Sp. z o. o., address Grochowska 306/ 308, 03-804 Warsaw, Poland – used for the purpose of ordering telephone connections with the call centre or for the purpose of website users establishing such connections,

I) the LiveChat tool – supplied by BespokeChat sp. z o. o., address Babiego Lata 13B/ 2C, 53-020 Wrocław, Poland – used for the purpose of direct contact with us via an on-line chat.

7) The Website uses plugins and other tools provided by social media sites such as Facebook or LinkedIn. By displaying a website that contains such plugins, the User’s browser establishes a direct connection with servers of controllers from such social media sites. The content of the plugin is transferred directly to the User’s web browser and integrated with the website. If the User is logged into one of the social media sites, then the service provider will be able to directly assign this visit on the Website to that particular profile on that particular social media site. Should the user click e. g. for instance the ‘Like’ button, then a relevant information shall also be sent directly to the server of that provider and stored there. In addition, this information shall be published on that specific social media site, shown e. g. on the Facebook wall. The purpose and scope of collection of the Data and of their further Processing and usage by the service providers, as well as the possibility of contact and the rights of the Users in this regard, as well as the possibility of adjusting settings ensuring protection of privacy are described in the privacy policy of the individual service providers. The Website also uses widgets (e. g. graphical information carriers) to transfer the user to the social media presences of the Controller.

8) The Website may contain links to websites belonging to or controlled by third parties. The Controller is not liable for the rules of processing of Personal Data by these third parties within the scope of other websites, including for the privacy policies, information clauses and other types of documents uploaded to these websites.

13. Cookie policy

1) The Controller automatically collects information stored in cookie files for the purpose of collection of Data related to the usage of the Website by the User. Cookie files are small pieces of text that the website sends to the User’s web browser, with the browser sending it back when the website is revisited. They are mainly used to maintain the sessions, e. g. by generating and returning a temporary identifier after logging in.

2) The Controller uses ‘session’ cookie files stored on the User’s end device until they log off, close the website or close the web browser, and ‘permanent’ cookie files stored on the User’s end device over the period described in the cookie file parameters, or until they are removed by the User.

3) Within the scope of the Website, the Controller uses the following cookie file types:
a) ‘strictly necessary’ cookie files that allow the usage of the services of the Website,
b) cookie files used to maintain security,
c) ‘performance’ cookies used to acquire information on the mode of usage of the Website pages by the Users,
d) ‘advertising’ cookies allowing the delivery to Users of advertising content that is better suited to their interests,
e) ‘functional’ cookies allowing storage of User settings and adaptation of the Website to the User.

4) The Controller uses external cookies for the following purposes:
a) collection of general and anonymous statistics via analysis tools: Google Analytics (cookie administrator: Google Ireland Ltd.),
b) advertising the Website using social media platforms (external cookie administrators: e. g. Meta Platforms Ireland with seat in Ireland),
c) presenting Users with e-mail advertisements that are adapted to their preferences, development of offers and recommendations on the basis of User activity on the Website; the reception of personalised advertisements/ offers is conditioned upon signing up to our Newsletter beforehand, and then the e-mail address is linked to the User using this tool’s cookies (cookie administrator: Sales Intelligence Sp. z o. o., address Jodłowa 1/ 3, 81-526 Gdynia, Poland),

5) The Controller ensures the possibility of usage of the social functionality such as subscribing to (observation of) a social media profile. The usage of this function may be related to the usage of cookie files of social metia administrators such as Facebook.

6) Cookie files adapt and optimise the Website and its offering to the needs of Users through such activities as developing Website display statistics and assuring security to its Users.

7) Cookie files are also necessary to maintain the User session after they leave the Website.

8) The User may change the settings of the cookie files at any time using their web browser, including blocking the possibility of collection of cookie files.

9) Blocking the possibility of collecting cookies or introduction of other changes to the cookie file settings on the User device may hinder or prevent using the Website services and tools.

10) A User who would not want cookie files to be used for the purposes described above may remove them manually at any time. In order to acquaint oneself with the specific mode of procedure in this regard one needs to visit the website of the developer of the browser the User uses. More information on cookie files is available in the help menu of every web browser. Example web browsers that support the mentioned cookie files are Mozilla Firefox, Google Chrome.

11) The Controller may allow external entities, e. g. advertisement suppliers or analysis solution suppliers to collect information using the above-described technologies directly on the Website pages. The Data collected in this way are subject to the provisions of the privacy policies developed by these entities.

14. Changes to the Privacy Policy

1) In the future, there may arise the need to introduce changes to or to update the Privacy Policy. This may become necessary in particular due to changes in binding provisions of the law concerning protection of Personal Data, guidelines concerning the protection of Personal Data issued by the supervisory body (Chairman of the Polish Data Protection Office), but also in relation to any possible changes in the Controller’s business or the Customer and Business Partner service processes.

2) The Controller guarantees that any changes to the Privacy Policy that may arise in the future shall remain in full agreement with valid provisions of the law in terms of protection of Personal Data, and will also take into account the necessity to ensure the security of Your Personal Data as Processed by the Controller.

3) An information on changes to the Privacy Policy shall be provided on the Website not later than within seven days before the updated version of the Privacy Policy would enter into force.