NETGEAR Privacy Policy

Last Updated : August 17, 2020

 

 

NETGEAR Inc., and its affiliates and subsidiaries (collectively, “NETGEAR” “we” “us,” or “our”) takes your privacy seriously. This Policy describes how we collect, use, disclose, transfer, and otherwise process the Personal Information of website visitors, consumer customers and other individuals who interact with us ("you", "yourself" or "your"). It also tells you about your rights with respect to your personal information, and how you can reach us to update it or get answers to questions you may have about our privacy practices.

1. Scope

This Policy applies to NETGEAR's processing of Personal Information, which means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable natural person such as yourself. Personal information does not include information that is de-identified or is in an aggregate, non-personally identifiable form.  

   (1) NETGEAR hardware products (including our routers and gateways, our ReadyNAS products and switches, and our Meural products) (“Products”),
   (2) All NETGEAR-owned websites and domains and website(s) that may be accessed at http://www.netgear.com/ and http://www.meural.com (“Sites”),
   (3) services, including technical support and services accessible through the Sites (“Web Apps”),
   (4) software that may be downloaded to your smartphone or tablet to access services (“Mobile Apps”), and
   (5) subscription services, including services you can access using the Web Apps and Mobile Apps (“Subscription Services”), (collectively, the “Services”).

Third parties may also integrate NETGEAR’s Products and Services into their products and services and we are not responsible for this integration.  Please remember that the manner in which these third parties use, store and disclose your information is governed by the policies that apply to these third parties' products and services. Since NETGEAR does not control the privacy policy of third parties, we encourage you to review the policies of any third party to whom you choose to share your personal information directly.

Additional information on our privacy practices may be provided in other documents such as offer descriptions, supplemental privacy statements, or notices provided prior to or at the time of data collection.

2. Quick links

We recommend that you read this Privacy Policy in full to ensure you are fully informed.  However, if you only want to access a particular section of this Privacy Policy, then you can click on the relevant link below to jump to that section.

1. Scope
2. Quick links
3. What does NETGEAR do?
4. What are Netgear's Data collection practices?
5. How We May Use Your Personal Information
6. How We Share Your Personal Information
7. Your Rights and Choices
8. Notice to California resident
9. Data Transfers
10. Privacy Shield Notice
11. Legal Basis for Processing
12. Alternate Privacy Policy Formats
13. How to Contact Us and How to Exercise Your Privacy Rights
14. Children’s Privacy
15. How We Protect Your Personal Information
16. Retention of Personal Information
17. Third Party Services
18. Update to this Notice

3. What does NETGEAR do?

NETGEAR is a leading provider of networking equipment, headquartered in the USA but with group companies all around the world.  At NETGEAR, we turn ideas into innovative networking products that connect people, power businesses, and advance the way we live. Easy to use. Powerful. Smart. And designed just for you.

For more information about NETGEAR, please see the “About Us” section of our Site.

4. What are NETGEAR's data collection practices?

The information we collect varies depending on which NETGEAR product or service you use. We have collected the following categories of personal information in the past twelve (12) months:  

  • Identifiers: 
    • This includes contact details, like your name, alias, mailing address, phone number or e-mail address, as well as your User ID, password hints and similar security information required for authentication and access to our platforms such as MyNETGEAR or Meural. We collect this information directly from you. For example, we ask you to provide your contact details in order to register an account with us (for example, on MyNETGEAR or Meural), to subscribe to marketing communications from us, apply for a giveaway or promotion or become a beta tester, and/or to submit inquiries to us.
    • We collect information you provide when you interact with us in-person, online, or by phone or mail with our help desks, online store and customer support channels, our responses to customer surveys or contests or additional information you provide to us to facilitate the delivery of our products and services, and to respond to your inquiries.
    • When you visit our Sites or use our Products and Services, we may also collect certain information automatically from your device, Web App(s) and/or Mobile App(s), such as your IP address, online identifiers, unique device identifiers, advertising identifiers, broad geographic location (e.g. country or city-level location) and other technical information. In some countries, including countries in the European Economic Area, this type of information may be considered personal information under applicable data protection laws.
    • In addition, we may also collect information (such as business contact details) from our stores, resellers or distribution partners, or from people you may know and refer you for jobs and other marketing materials. Please note that in these instances, we check with the third parties to ensure they have obtained your prior consent or are otherwise legally permitted or required to disclose your personal information to us.
  • Customer records information: 
    • This includes information such as your name, signature, address, telephone number, employment, employment history, bank account number, credit card number, debit card number, or any other information which constitutes customer records in accordance with applicable law. We collect this information directly from you.
    • For example, we collect your debit or credit card number when you buy products or purchase a subscription to use one of our products or services, for shipping services related to a warranty replacement, or when you buy/license an application from the NETGEAR App Marketplace.
  • Characteristics of protected classifications in certain jurisdictions (e.g. under California or federal law): This includes demographic information, which may include sex (such as gender and gender identity), age, race and/or ethnicity.
  • Commercial information: This includes information such as records of NETGEAR products or services that you purchased, obtained, or considered. We collect this information directly from you.
  • Internet or other network activity information:
    • This includes information such as Internet speed, error rates, app download and usage, firmware version, configuration settings, Wifi settings, Internet speed, voltage information, storage information, error rates, App download and usage, services and feature usage, crash diagnostics, and other performance information. We collect this information directly from your device.
    • Collecting this information enables us to better understand the visitors who come to our Sites and customers who use our Products and Services and what content and/or feature(s) is relevant and of interest to them. We also collect this information to provide you with the appropriate upgrade(s) and support and to improve our Products and Services.
    • Some of this information may be collected using cookies and similar tracking technology. Third parties may also collect information using cookies. Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. To learn more about our cookie policy, click here.
  • Geolocation data: This includes broad geographic location (e.g. country or city-level location). We collect this information directly from your device.
  • Audio, electronic, visual or similar information: This includes information such as chat, images and audio, video or call recordings created when you contact us, such as when you contact our customer service team for support or assistance. We collect this information directly from you.
  • Professional or employment-related information: This includes information such as your business contact details in order to provide services at a business level. We may also collect your contact details and information about your professional qualifications, including your curriculum vitae and references when you apply for a job with NETGEAR. We collect this information directly from you, or from the job applicant in the case where you have been provided as a reference by a job applicant, by the job applicant.
  • Inferences: this includes information inferred from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
  • Electronic and usage information:
    • This includes information about how your device has interacted with our Site, including the pages accessed and links clicked, or our products. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identifiers, firmware and software versions, registration and configuration settings, services and feature usage, crash diagnostics and performance information, advertising identifiers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.
    • We also collect functional data if you use our Meural products, including product type, device type, controller operating system, software version, information about WiFi antennas, backlight settings, product orientation, the names you have given your Meural product in different rooms, and error information. We collect this information to help ensure that your Meural product(s) and devices are working properly, to provide you with customer support and to honor your visual art preferences. We also collect this information to guide product and device improvement and customer support decisions.
    • In addition, our Meural products collect activity information, such as duration of image viewing, image downloads, device grouping (if multiple devices on a single registered account) information, command information (such as image rotation, brightness adjustment, schedule settings, and image rotation), information about playlist data; and Meural playlist or Meural favorites information; each correlated to individual Meural devices. If you enable voice control, we will collect comparable information about usage and control. We collect this information directly from your device.

We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:

  • Receiving help through our help desks or other customer support channels
  • Participation in customer surveys or contests
  • Facilitation in the delivery of our services and to respond to your inquiries

In these instances, we collect this information directly from you.

From time to time, we may receive personal information about you from third party sources such as:

  • Social Media Platforms for example, if you access our Services using your Facebook account login, we may receive Personal Information about you such as your name, email address, and gender. Any Personal Information that we collect from your Facebook account may depend on your Facebook account’s privacy settings.
  • Online Stores, Retail Stores, Authorized Resellers, Distribution Partners if you purchase NETGEAR Products or Services from one of these partners, we may receive information about you and your purchase.
  • Service partners with whom we offer co-branded services such as security and parental control software, or engage in joint marketing activities.
  • Marketing partners that work with us on social media and online channels to sponsor giveaways and promotions.
  • Third parties personal information: if you choose to provide us with a third party's Personal Information (such as name, email, and phone number), you must ensure that you have the third party's permission to do so. Examples include providing us with the names and images that you associate with account users, forwarding reference or marketing material to a friend, or sending job referrals.

We only collect information from third parties where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

5. How We Use Your Personal Information

At NETGEAR, we only use your Personal Information for legitimate business purposes. Such purposes include:

a. To provide you with the Services you requested or subscribed to and communicate with you in connection with those Services. We will use your Personal Information to deliver our Services and to interact with you directly.

b. To maintain, improve and develop our Products and Services. We will use your Personal Information to ensure our Products and Services are working as intended and to make improvements to our Products and Services.  We will also use the information we collect in existing Services to help us develop new ones or to customize Services for you.

c. Internal data analyses. We use Personal Information for internal analytics to understand how our Services are used.

d. Marketing. We may send you marketing communications about products, services, offers, programs and promotions (including contests, sweepstakes and any other marketing activities) either directly from us or from our partners. These might be our own offers or products, or offers for third-party products we think you might find interesting, but we do not share information with third parties for their independent marketing or promotional purposes.

e. Protect our company, prevent fraud and securing our products. We may use your Personal Information to protect our company, our customers, or our Sites. 

f. Compliance with law and other standards. We may use your Personal Information as required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over NETGEAR or its affiliates. 

g. To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that information to respond to your inquiry. If you contact us in relation to support for a Product or Service, we will use your Personal Information to provide you with support and to respond to your inquiries, including investigating, addressing your concerns, monitoring and improving our responses.

h. Other activities.We may process your Personal Information for other purposes for which we provide specific notice at the time of collection.

6. How We Share Your Personal Information

At NETGEAR, we only share your Personal Information when we have legitimate business reasons for doing so. In the past twelve (12) months, we have shared and share the following categories of Personal Information (in each case, the categories of Personal Information are further explained in Section 4 above titled "What are NETGEAR's data collection practices?"):

  • Identifiers;
  • Customer records information;
  • Characteristics of protected classifications in certain jurisdictions (e.g. under California or federal law);
  • Commercial information;
  • Internet or other electronic network activity information;
  • Geolocation data;
  • Audio, electronic, visual or similar information;
  • Professional or employment-related information;
  • Inferences; and
  • Electronic and usage information.

We share these categories of Personal Information for our business purposes (listed in Section 5 above, titled "How We Use Your Personal Information") in the following ways, or as otherwise disclosed to you at the time of data collection:

a. Within the NETGEAR family of companies worldwide. We may share the Personal Information we collect with our headquarters and affiliates.

b. With our vendors, service providers, agents and representatives. We may share Personal Information with our vendors, service providers, agents, representatives, resellers, distributors, referral partners and integrators who support our business and perform services on our behalf based on our instructions and in compliance with appropriate confidentiality and security measures. Examples of services include: processing of orders and credit card transactions, detecting and preventing fraud, providing customer support, creating marketing content, and assisting us with sales-related efforts or post-sales support. This also includes our service partners with whom we offer co-branded services such as security software, or engage in joint marketing activities. For example, if you purchase our 'Netgear Armor Powered by Bitdefender' solution, we share Personal Information with Bitdefender in connection with your subscription and the operation of the solution.

c. With the administrators authorized by your organization (if you access our services through a subscription administered by your organization). For example if your organization has subscribed to one of our Software-as-a-Service (SaaS) platforms, we may share Personal Information with the administrators authorized by your organization to manage the use of the platform within your organization.

d. We may share information with any successor to all or part of our business. We may sell, transfer or otherwise share some or all of its assets, including Personal Information, in connection with a merger, acquisition, reorganization, sale of assets, spin off of assets into a separate business, or similar transaction, or in the event of insolvency or bankruptcy. Should such an event occur, we will use reasonable efforts to direct the transferee to use Personal Information you have provided to us in a manner that is consistent with this Privacy Policy.

e. We may share information for legal reasons. We will share Personal Information with companies, organizations or individuals outside of NETGEAR if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

  • meet any applicable law, regulation, legal process or enforceable governmental request;
  • enforce applicable Terms of Use, including investigation of potential violations;
  • detect, prevent, or otherwise address fraud, security or technical issues;
  • protect or defend our rights, or for our operational business purposes; or
  • protect against harm to the rights, property or safety of NETGEAR and its employees, our users or the public as required or permitted by law.

f. Others. If we otherwise notify you and you consent to the sharing.

7. Your Rights and Choices

Depending on your country or state of residence, you have certain rights regarding the Personal Information we maintain about you and certain choices about what Personal Information we collect from you, how we use it, and how we communicate with you.

  • The right of access means that you have the right to request that we disclose what personal information we have collected, used and disclosed about you. You can do so at any time by contacting us using the contact details provided under the "How to Contact Us and How to Exercise Your Privacy Rights" heading below.
  • The right of deletion means that you have the right to request that we delete personal information collected or maintained by us, subject to certain exceptions. As mentioned above, you can do so at any time by contacting us using the contact details provided under the "How to Contact Us and How to Exercise Your Privacy Rights" heading below.
  • The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
  • You can also ask us to correct or update your personal information; object to the processing of your personal information,; ask us to restrict processing of your personal information or request the portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the "How to Contact Us and How to Exercise Your Privacy Rights" heading below.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the "How to Contact Us and How to Exercise Your Privacy Rights" heading below. We do not share information with third parties for their independent marketing or promotional purposes. 
  • Similarly, if we have collected and process 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.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

8. Notice to California residents

As mentioned above, NETGEAR may provide third parties with certain personal information to provide or improve our products and services, for example to deliver products or services at your request. In such cases, we require those third parties to handle the information in accordance with applicable laws and regulations.

NETGEAR does not sell personal information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018), nor does NETGEAR share personal information with third parties for their direct marketing purposes (pursuant to California Civil Code Sec. 1798.83).

Financial Incentives

From time to time, we may offer financial incentives, such as coupons, discounts or other price reductions, for our products and services in exchange for your enrolment in email updates, newsletter delivery, contests, or similar communications. The amount or nature of the coupon, discount or other price reduction will be specified in each instance at the time the personal information is to be submitted. To receive these financial incentives, you will be asked to provide certain personal information, for example to provide your email address in order to receive a discount coupon or to provide your details in order to participate in a contest. You can opt into the financial incentive by submitting your personal information. If you do not wish to opt into the financial incentive, do not submit the personal information.

You can opt out of the financial incentive at any time. To do so, please use the contact information provided below in Section 13 to submit a request, or by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.

9. Data Transfers

NETGEAR is a global business.  We may transfer your Personal Information to recipients in countries other than your country, including the United States, where we are headquartered. These countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your Personal Information to other countries, we will protect that information as described in this Privacy Policy or as disclosed to you at the time of data collection.  By using our Sites, Products, and Services or providing any Personal Information, where applicable law permits, you agree to the transfers, processing, and storage of your Personal Information outside of your country of residence. 

If you are located in the European Economic Area, ("EEA"), we comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Information to countries other than the country where you are located. In particular, we use contractual protections for the transfer of Personal Information to third parties, such as the European Commission’s Standard Contractual Clauses. 

10. Privacy Shield Notice

NETGEAR complies with the EU-US and the Swiss-US Privacy Shield Frameworks ("Privacy Shield") as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from EU member countries, the United Kingdom, and Switzerland. NETGEAR certifies that it adheres to the Privacy Shield principles on notice, choice, accountability for onward transfer security, data integrity and purpose limitation, access, and recourse, enforcement and liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov/list.

NETGEAR’s responsibility for data it receives pursuant to the Privacy Shield and subsequent transfers of that data to third parties is detailed in the Privacy Shield Principles. NETGEAR complies with the Privacy Shield Principles for all onward transfers from the EU and Switzerland, including the onward transfer liability provisions. NETGEAR remains responsible under the Privacy Shield Principles for third-party agents processing personal data on its behalf.

With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

NETGEAR commits to resolving complaints about your privacy and our collection and use of your personal information within 45 days of receiving your complaint. Individuals with questions or complaints regarding this Privacy Policy should first submit inquiries via e-mail to privacypolicy@netgear.com. For any unresolved privacy complaints under the Privacy Shield Principles, please contact NETGEAR’s independent dispute resolution body, JAMS, https://www.jamsadr.com/eu-us-privacy-shield). Under limited circumstances, binding arbitration may be a dispute resolution mechanism if your complaint is not resolved through these channels. Please visit the Privacy Shield website for additional information about the arbitration process at www.privacyshield.gov.

11. Legal Basis for Processing

If you are located in the EEA, we process your Personal Information for the purposes listed under Section 5 above titled "How We Use Your Personal Information" based on the following legal grounds:

a. You have consented to the use of your Personal Information. For example, we may seek to obtain your consent for our uses of cookies when you visit our Site, or to send you marketing communications.

b. We need your Personal Information to provide you with Products and Services requested by you, or to respond to your inquiries.

c. We have a legal obligation to use or disclose your Personal Information, for example, if we are responding to a legal process or an enforceable governmental request.

d. We (or a third party) have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for things like:

  • Providing, maintaining, and improving our Services to meet the needs of you and other users;
  • Developing new products and features that are useful for you and our other users;
  • Understanding how people use our Services to ensure and improve the performance of our Services;
  • Customizing our Services to provide you with a better user experience;
  • Marketing to inform existing customers about our Services;
  • Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our Services;
  • Protecting against harm to the rights, property or safety of NETGEAR, our users, or the public as required or permitted by law;
  • Performing research that improves our services for our users and benefits the public;
  • Fulfilling obligations to our partners like developers and rights holders; and
  • Enforcing legal claims, including investigation of potential violations of applicable Terms of Use.

In addition, if we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

NETGEAR, Inc, together with NETGEAR International Limited acting as its EU Representative, is the entity responsible for the processing of your Personal Information

12. Alternate Privacy Policy Formats

If you are unable to access this Policy due to a disability or any physical or mental impairment, please contact us using the contact details in the next section below and we will arrange to supply you with the information you need in an alternative format that you can access. You can also access a printable version of this Policy here

13. How to Contact Us and How to Exercise Your Privacy Rights

You can exercise your rights yourself or, depending on your country or state, you may be able to designate an authorized agent to exercise these rights on your behalf. Please note that to protect your personal information, we will verify your identity by a method appropriate to the type of request you are making. For example, this could include sending an e-mail to an account on record, or asking you to identify a recent transaction or communication. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your personal information.

To exercise your rights provided under this Policy, please submit your request via this Web Form.

You could also use the contact details below, if you would like to:

  • Access this policy in an alternative format;
  • Exercise your rights;
  • Learn more about your rights or our privacy practices; or
  • Designate an authorized agent to make a request on your behalf.

E-mail: privacypolicy@netgear.com or write to us at: 

NETGEAR Inc.

350 East Plumeria Drive

San Jose,

CA 95134

USA

 

Or

NETGEAR International Limited

First Floor, Building 3, University Technology Centre

Curraheen Road

Cork

Ireland

 

You can also call our Toll-Free telephone number at: 1-866-203-9039

You may also contact our Data Protection Officer at dpo@netgear.com.

14. Children’s Privacy

Our Products and Services are meant for adults. We do not knowingly allow children under 16 to set up NETGEAR or Meural accounts. If you are under 16, do not use the Sites or Services. If we learn that we have collected or received personal information from a child under 16 without parental consent, we will delete that information. If you believe that we may have collected Personal Information from someone under 16, please let us know using the methods described in the Contact Us section and we will take appropriate measures to investigate and address the issue promptly

Certain NETGEAR’s products are also equipped with parental control features. To learn more about them, click .

15. How We Protect Your Personal Information

We intend to protect the Personal Information entrusted to us and treat it securely in accordance with this Privacy Policy. We maintain administrative, technical and physical safeguards to protect Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. We also contractually require that our suppliers protect such information from unauthorized access, use, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Sites or Services, you are responsible for keeping this password confidential and not sharing it with anyone. We also encourage you to use caution when using the Internet as it is not 100% secure. Accordingly, we cannot guarantee the security of your personal information transmitted electronically and we cannot promise that your use of our Sites and Services will be completely safe. Any transmission of personal information is at your own risk. We are also not responsible for circumvention of any privacy settings or security measures contained on the Sites.

If you participate in a discussion forum, local communities, or chat room on a NETGEAR website, you should be aware that the information you provide there (i.e. your public profile) will be made broadly available to others, and could be used to contact you, send you unsolicited messages, or for purposes neither NETGEAR nor you have control over. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. NETGEAR is not responsible for the Personal Information or any other information you choose to submit in these forums. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

16. Retention of Personal Information

We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it or when you request its deletion, unless we are allowed or required by law to keep the information for a longer period. We complete periodic reviews of our databases, and have established time limits for certain data deletion, taking into account the type of services provided in the context of the Products and Services, the length of our relationship with you, mandatory retention periods, and the statute of limitations.

17. Third Party Services

Our Services may contain features or links to websites and services provided by third parties. If you click on a link to a third party site, you will be taken to a website(s) we do not control. These links are provided for your information and convenience only and are not an endorsement of the content of such linked websites or third parties. Any information you provide on third-party sites or services may be provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through us. This Policy does not apply to the privacy practices of that website. We encourage you to read the privacy policy of such website carefully. We are not responsible for third party sites or services to which links or access are provided through our Services, nor are we responsible for their content or availability.

18. Updates to this Policy

We may update this Privacy Policy from time to time. If we modify our Privacy Policy, we will post the revised version here, with an updated revision date. We recommend that you visit these pages periodically to be aware of and review any such revisions. If we make material changes to our Privacy Policy, we may also notify you by other means prior to the changes taking effect, such as by posting a notice on our Sites or sending you a notification.