Privacy Policy of Climate Connect gUG (haftungsbeschränkt)

as revised on February 2023

1.Scope of application

Climate Connect gUG (haftungsbeschränkt) (herewith Climate Connect or we) is committed to protecting your privacy and personal data. With this privacy policy we would like to inform you in detail about how we use your personal data. This privacy policy applies to the use of your personal data when you visit our websites available at [www.climateconnect.earth] and when you contact us by e-mail, telephone, if you maintain a business relationship with us or use our services.

2.Who is responsible and to whom can I reach out?

Climate Connect gUG (haftungsbeschränkt), Berliner Straße 9b, 91301 Forchheim, Germany, entered in the Commercial Register of the District Court of Bamberg under the registration number HRB 10578, represented by Christoph Stoll, Tobias Wilhelm Rehm and Thomas Bove, is responsible for the processing of personal data described in this privacy policy.

You can contact the following office for all inquiries related to data protection:

Climate Connect gUG (haftungsbeschränkt)

Berliner Straße 9b

91301 Forchheim

Germany

Tel. +49 157/30101056

E-mail: contact@climateconnect.earth

We are not legally obliged to appoint a data protection officer. As a contact person for data protection issues, you are welcome to contact:

Climate Connect gUG (haftungsbeschränkt)

Tobias Rehm

Berliner Straße 9b

91301 Forchheim

Germany

Tel. +49 157/30101056

E-mail: tobias.rehm@climateconnect.earth

3. Which data do we process from you?

We collect and process various personal data from you depending on the specific processing situation. Below you will find a list of the data related to the respective processing situations.

3.1 What data do we process when you visit our websites?

You can visit our websites without disclosing your identity. If you use the services provided by Climate Connect on the websites without registering, we will process, inter alia, the following data from you:

3.2 Which data do we process when you contact us?

Depending on your request, you can contact us via our websites or outside the Internet, either by telephone or in writing. We only store and process your e-mail address, telephone number, postal address, and other information that you have provided to us.

We process data when you provide feedback or post user content on our site. For example, if you post a project or a comment on our website or a comment on our social media sites, your information, such as your account name and your comments, may be displayed on our website or on our social media pages.

3.3 Which data do we process when you register?

On our website, we offer you the possibility to register by entering personal data. The data will be entered into an input mask, transmitted to us and stored. The data will not be passed on to third parties. The following data is collected during the registration process:

(1) clear name or pseudonym

(2) e-mail address

(3) location

(4) password

At the time of registration, the following data is also stored:

(1) IP address of the user

(2) date and time of registration

Climate Connect presents awards to users who have made achievements (for example, who have distinguished themselves through regular donations or a variety of comments and projects or if you have signed up during the alpha and beta phase of Climate Connect). These awards are visible in the userprofiles and next to user names and are based on the automatic data analysis of the respective category for the relevant award.

3.4 Which data do we process in the context of a donation to us?

If you want to make a donation to us, you can do so by using the donation form of twingle, by bank transfer or by using the payment service Paypal. Depending on the type of transaction, the following data will be processed :

(1) clear name

(2) address

(3) bank details

(4) e-mail address

(5) company name

3.5 Which data do we process when you reister for our newsletter?

If you register for our newsletter, we may process further information from you in addition to your e-mail address that you have provided us with in connection with the registration. In particular, we process all information required to prove that you have registered for the newsletter. We distributeour newsletter via Mailjet

4. From whom do we collect your personal data?

Personal data is only collected directly from you, e.g., by visiting our websites or using the services offered, such as the possibility of registration, using our newsletter and contacting us by e-mail.

5. For what purposes and on what legal basis do we process your data?

We process your personal data exclusively in accordance with the provisions of the General Data Protection Regulation (GDPR), and the Federal Data Protection Act (Bundesdatenschutzgesetz) (BDSG). In certain situations, we also process your personal data to fulfill other legal obligations or based on your explicit consent.

5.1 For the performance of a contract

We process our personal data in order to provide the services of our website, in particular for the networking of users among each other and the projects provided, in line with Article 6 (1), first sentence e) GDPR.

5.2 To be in compliance with legal obligations

To the extent that we are subject to legal obligations, for the compliance of which the processing of your personal data is necessary, we process your personal data on the basis of these legal obligations in line with Article 6 (1), first sentence e) GDPR.

5.3 Based on our legitimate interests

We also process your personal data to protect our legitimate interests in line with Article 6 (1), first sentence f) GDPR, except where your interests or fundamental rights and freedoms, which require the protection of your personal data prevail. Subject to a decision to be made in individual cases, we usually assume that our legitimate interests prevail within the context of the following processing situations, which are not listed exhaustively:

5.4 Based on your consent

If you have given us separate consent to process your personal data, we will process your personal data within and on the basis of this consent. Consents may, for example, relate to the registration, or sending of newsletters, in line with Article 6 (1), first sentence a) GDPR. Consent is always freely given. Refusing or revoking your consent will not have any negative consequences for you. As part of the registration process, the user’s consent to the processing of his data is obtained. User registration is required for the provision of certain contents and services on our website. The registration serves the networking of the users among themselves and the possibility of posting projects and interacting within this context.

6. To whom do we transfer your data?

We transfer your personal data to the extent necessary for the formation, execution or termination of an agreement or quasi-contractual legal relationship, in principle, within the scope of the processing described below. We will share your personal information with the following categories of recipients for the purposes set out above:

6.1 Transfer based on legal obligations or for the protection of legitimate interests

To the extent we are obliged to do so by law, court order, or by an enforceable official order, we will transfer your personal data to bodies entitled to receive information.

6.2 Other transfers

If you have given us a separate consent form to use and transfer your personal data, your personal data may be passed on to the recipients named therein. As part of the provision of third-party services on our websites, personal data may be passed on to third parties. In addition, no personal data will be transferred on to third parties unless, in individual cases, there is a specific legal justification for the transfer, and your interests or fundamental rights and freedoms do not prevail.

7. Do we transfer your data to third countries?

For some types of processing, we may transfer your personal data to countries outside the European Union or the European Economic Area, to so-called third countries. In the course of a transfer of personal data to a third country, we will regularly provide appropriate guarantees, for example, by concluding the Standard Contractual Clauses of the European Commission to ensure that the transfer of data takes place with the same level of data protection that corresponds to the GDPR.

8. How long do we store your personal data?

We process and store your personal data only as long as necessary for our processing purposes.

Upon request, we will regularly delete the data collected and stored for our websites’ usage at any time. We will do this ourselves and within a few days, unless we have a particular interest in continuing storage for individual cases, e.g., cyberattacks.

Regarding your contact requests, we only store your data for the time period necessary to answer your request. If you have registered for our newsletter, we process your data in this connection for the duration of your registration for your newsletter and delete it at any time if you unsubscribe from our newsletter.

If you have registered at our website, the data is deleted as soon as it is no longer required for the purpose of its collection. This is the case for the data collected during the registration process if the registration on our website is cancelled or modified. The personal data collected during the registration process is usually deleted after a period of 30 days in order to enable the registration to be restored after misuse or unauthorized use of data by third parties (hacking).

As a user you have the possibility to cancel the registration at any time by using the delete option in the settings. You can have the data stored about you changed at any time.

Insofar as a longer retention period is required by statutory retention and documentation obligations or to protect our legitimate interests, e.g., in the event of possible legal disputes, your personal data will be stored and processed even after the above-mentioned period has expired. With complete execution of a contract or quasi-contractual relationship, we will, as far as possible, immediately restrict your personal data from further processing.

A final deletion takes place after the legal retention and documentation obligation periods expire, which are between two and ten years and result, inter alia, from the Fiscal Code of Germany (Abgabenordnung) or German Commercial Code (Handelsgesetzbuch).

9. Your rights

In the following, you will find a summary of your rights regarding the processing of your personal data:

9.1 Rights to access, delete, correct, restrict processing, and portability of your data

According to Article 15 GDPR, you have the right to obtain confirmation from us as to whether or not personal data concerning you is being processed by us. Where that is the case, you have a right to access the personal data and obtain further information.

According to Article 16 GDPR, you may have the right to obtain the rectification of inaccurate personal data concerning you without undue delay.

According to Article 17 GDPR, you may have the right to obtain erasure of personal data concerning you if (i) it is no longer necessary in relation to the purpose for which it is collected, (ii) you have withdrawn your consent on which the processing is based, (iii) you have objected to the processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (2) GDPR, (iv) your personal data has been unlawfully processed; (v) the personal data has to be erased for compliance with a legal obligation to which Climate Connect is subject , or (vi) the personal data has been collected in relation to the offer of information society services pursuant to Article 8 (1) GDPR.

According to Article 18 GDPR, you may have the right to obtain the restriction of processing. Such right shall exist if (i) you contested the accuracy of the personal data, (ii) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead, (iii) the personal data is no longer needed for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims, or (iv) you have objected to processing pursuant to Article 21(1) GDPR pending the verification of whether our grounds legitimately override yours.

According to Article 19 GDPR, you have the right to obtain information about the recipients of data to whom the rectification, erasure, or restriction of processing has been communicated.

According to Article 20 GDPR, you have the right to obtain personal data concerning you in a structured, commonly used and machine-readable format and to transmit the data to another controller.

If the processing or transfer of your personal data is based on a consent given by you, you can withdraw your consent at any time with effect for the future.

You have the right to lodge a complaint against the processing of your data or any decision of Climate Connect in relation to one of your rights you have exercised, to the supervisory authority at your place of business or the Bavarian State Office for Data Protection Supervision (Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)), Promenade 18, 91522 Ansbach.

9.2 Contact

To exercise your rights under section 9.1, you can contact us without any formality by post or e-mail at the points of contact listed in section 2.

9.3 RIGHT TO OBJECT PURSUANT TO ARTICLE 21 DSGVO

ACCORDING TO ARTICLE 21 (1) GDPR, YOU HAVE THE RIGHT TO OBJECT, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, AT ANY TIME, TO PROCESSING OF PERSONAL DATA CONCERNING YOU WHICH IS BASED ON OUR LEGITIMATE INTERESTS. WE SHALL NO LONGER PROCESS THE PERSONAL DATA UNLESS WE DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE THE INTERESTS, RIGHTS, AND FREEDOMS OF YOU, OR FOR THE ESTABLISHMENT, EXERCISE, OR DEFENSE OF LEGAL CLAIMS. YOU CAN SEND YOUR OBJECTION INFORMALLY BY POST, FAX OR E-MAIL ADDRESSED TO:

Climate Connect gUG (haftungsbeschränkt)

Management

Berliner Straße 9b

91301 Forchheim

Deutschland

TEL. + 49 (0) 157/30101056

E-MAIL contact@climateconnect.earth

10. Is there any obligation on your side to provide personal data?

There is neither a contractual nor a legal obligation to provide us with your personal data for the use of our websites, however, in case of a donation, we may be obliged to issue donation conformations and use your personal data in this context. Also, if you wish to contact us, certain information may be required to enable us to process your request.

11. Is the processing based on automated decision-making or profiling?

You have a right not to be subject to a decision based solely on automated processing, including profiling, if the decision is not necessary for the conclusion or performance of a contract, is not required by mandatory law, or is not based on your explicit consent. Climate Connect does not use automated decision-making procedures, including profiling, unless we have explicitly informed you of them.

12. What kind of cookies and tracking technology do we use?

For the provision, maintenance, and analysis of our websites and their usage, we use various software tools from third parties and ourselves, which are regularly based on the use of cookies, Flash cookies (also called Flash Local Shared Objects), web beacons or similar technologies (collectively as "Tracking Technologies").

Tracking Technologies can help us understand how you use our services (e.g., the pages you display or the links you click and other actions you perform with the services), give us information about your browser and online usage patterns (e.g., IP address, log data, browser type, browser language, referring/exiting pages and URLs, pages viewed, whether you have opened an e-mail, clicked links, screen resolution, page generation time, locations of user, etc.) as well as information about the devices with which you access our services. Tracking Technologies allow us to link the devices you use to access our services so that we can identify and contact you on the various devices you use.

You can limit the use of Tracking Technologies by changing the settings of your browser. You can determine what access you grant us and whether and for how long cookies can be stored on your device. You can also delete cookies that have already been stored at any time. Please note that the functionality of our websites may be affected after deactivating all cookies. Similar functions (such as Flash cookies), which are used by so-called browser add-ons, can be switched off or deleted by changing the settings of the browser add-on or via the website of the browser add-on provider.

12.1 What are cookies?

A cookie is a small file that is transferred during the use of a website from the host server of the website and stored on the user's device (desktop computer, laptop, tablet, smartphone, other Internet-enabled devices) by the browser used. Cookies are used to store information about the user and to retrieve it when the website is called up again.

12.2 What are cookies used for?

Cookies help us understand the use of our websites, analyze trends, administer the websites, track a user's steps on our websites, collect demographic information about our user base as a whole, allow you to navigate efficiently between the pages, remember your preferences and settings on our websites, and generally improve your browsing experience. We process the data collected using Tracking Technologies to (i) remember information so that you do not have to re-enter them during your visit or a new visit, (ii) recognize you across multiple devices, (iii) control the functionality and performance of our websites, (iv) collect aggregated metrics regarding the total number of visitors, total traffic, usage and demographic patterns on our websites, (v) diagnose and resolve technical issues, and (vi) otherwise plan and improve our website.

12.3 What types of cookies are used on our websites?

The cookies used on our website can usually be categorized as follows: mandatory cookies, analytical cookies, and function-related cookies.

12.3.1 Mandatory Cookies

These cookies are essential for the functioning of our websites and enable you to move around our websites and to use their functions. Without these cookies, certain services that are required for the full functioning of our websites cannot be provided.

12.3.2 Analytical Cookies

With the help of these cookies, we collect information about how our users use our websites, e.g., which pages are accessed and read most frequently, or how users move from one link to the next. All information collected by this type of cookie does not relate to a single user but is aggregated and processed with the information of other users. Cookies provide us with analytical data on how our websites work and how we can improve them.

12.3.3 Function-related Cookies

These cookies allow us to save a specific selection you have made and to adapt our website in such a way that it offers you extended functions and content. These cookies can be used, for example, to save your language selection or country selection.

12.4 How long are cookies stored on my device?

The retention period depends essentially on whether the cookie is persistent or session-based. Session-based cookies are deleted after you leave the websites that set the cookie. Persistent cookies remain on your device even after you have finished browsing until they are deleted or until they have expired.

12.5 Third party tracking and online services

For the provision of our website we use the services of the third-party providers listed below. These third-party tools belong partly to the categories of the cookies described above and help us provide our services on our website or to promote our products and services over the internet. We share or allow Google Analytics, Google Ads, Twingle Matomo, YouTube, Webflow, Nominatim, Microsoft Azure and Mailjet to collect information about your use of our website over time. The information we share is only provided through cookies or similar web tracking technologies that recognize the device you are using to collect information, including click stream information, browser type, time and date you visited the site, whether you logged into your account for our services, or otherwise worked with us. The following provides additional information about these third parties:

12.5.1 Google Analytics

This website uses the "Google Analytics" service, which is provided by Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA), to analyze website usage by users. The service uses cookies. The information collected by the cookies is usually sent to a Google server in the USA and stored there.

IP anonymization is used on this website. The IP address of the user is shortened within the member states of the EU and the European Economic Area. This shortening eliminates the personal reference of your IP address. As part of the agreement on the order data agreement, which the website operators have concluded with Google Inc., the latter uses the information collected to create an evaluation of website use and website activity and provides services associated with internet use.

You have the option of preventing the cookie from being stored on your device by making the appropriate settings in your browser or user profile. It is not guaranteed that you will be able to access all features of this website without restrictions if your browser does not allow cookies.

Furthermore, you can use a browser plug-in to prevent the information collected by cookies (including your IP address) from being sent to and used by Google Inc. The following link will take you to the corresponding plugin: https://tools.google.com/dlpage/gaoptout.  

Here you can find more information about the use of data by Google Inc.: https://support.google.com/analytics/answer/6004245

12.5.1 Google Ads

This website uses the "Google Ads" service, which is provided by Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA), to analyze website usage by users. The service uses cookies. The information collected by the cookies is usually sent to a Google server in the USA and stored there.

IP anonymization is used on this website. The IP address of the user is shortened within the member states of the EU and the European Economic Area. This shortening eliminates the personal reference of your IP address. As part of the agreement on the order data agreement, which the website operators have concluded with Google Inc., the latter uses the information collected to create an evaluation of website use and website activity and provides services associated with internet use.

You have the option of preventing the cookie from being stored on your device by making the appropriate settings in your browser or user profile. It is not guaranteed that you will be able to access all features of this website without restrictions if your browser does not allow cookies.

Furthermore, you can use a browser plug-in to prevent the information collected by cookies (including your IP address) from being sent to and used by Google Inc. The following link will take you to the corresponding plugin: https://tools.google.com/dlpage/gaoptout.  

Here you can find more information about the use of data by Google Inc.: https://support.google.com/analytics/answer/6004245

12.5.2 Twingle Matomo

In the donation form of twingle, data is collected and stored using the web analysis service software Matomo (www.matomo.org) , a service of the provider InnoCraft Ltd, 150 Willis St, 6011 Wellingtion, New Zealand based on twingle’s legitimate interest in statistical analysis of user behaviour for optimisation purposes. This data can be used to create and evaluate pseudonyms, user profiles for the same purpose. Cookies may be used for this purpose. Among other things, the cookies enable the recognition of the internet browser. The data collected with Matomo Technology (including your pseudonymized IP address) is processed on twingle servers. The information generated by the Cookie in the pseudonymous user profile is not used to personally identify the visitor of the website an is not merged with personal data about the bearer of the pseudonym. If you do not agree with the storage and evaluation of these data from your visit, you can object to the storage and use of these data at any time by using the banner that that appears when twingle is used.

12.5.3 YouTube

On our website we use the services of the video portal YouTube LLC, 901 Cherry Ave., 94066 San Bruno, CA, USA, (“YouTube”) for the integration of videos. In connection with the provision of YouTube, we use the “Extended Privacy Mode” which is intended to ensure that data is only transferred to YouTube when the videos are accessed.

Without the “Enhanced Privacy Mode” a connection would be established to YouTube’s server when you visit our websites where a video is embedded. A connection to YouTube is required in any case in order to retrieve and display a video. In this context YouTube stores at least the IP address, the date and the times as well as the website you visited. Furthermore, a connection to advertising network “DoubleClick” of Google is established.

If you are logged in to YouTube at the time of your visit to our website, YouTube can establish a connection to your YouTube account. To prevent this, you must either log out of YouTube before visiting our sites or change the settings in your YouTube account. 

For the purpose of ensuring improved usability and the analysis of usage behavior, YouTube permanently stores cookies via your internet browser on your end device. If you do not agree with this processing, you have the possibility to prevent the storage of cookies by adjusting your internet browser settings. You will find more information on this in the section “Cookies” listed above. 

Further information on the collection and use of data and your rights and protection options in this regard is provided by Google in the data protection information available at: https://policies.google.com/privacy

12.5.5 Webflow

The provider is Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA (hereinafter Webflow). When you visit our website, Webflow collects various log files including your IP addresses on certain pages.

Webflow is a tool for creating and hosting websites. Webflow stores cookies or other recognition technologies that are necessary for the presentation of the page, to provide certain website functions and to ensure security (necessary cookies).

For Details, see Webflow's privacy policy: https://webflow.com/legal/eu-privacy-policy.

The use of Webflow is based on Art. 6 para. 1 lit. f DSGVO. We have a

legitimate interest in ensuring that our website is presented as reliably as possible. Insofar as a

corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) as defined by the TTDSG. The consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission.

Details can be found here:https://webflow.com/legal/eu-privacy-policy.

12.5.6 Nominatim

Our Website uses the geocoding service of OpenStreetMaps via the API Nominatim. To use the geocoding function when searching for and creating projects, organizations and members, the location data entered is transmitted to Nominatim for the determination of coordinates.

The use of Nominatim is in the interest of an appealing presentation of our online offers and easy location of the places indicated on the website. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO.

More information on the handling of user data can be found in the privacy policy of OpenStreetMaps: https://wiki.osmfoundation.org/wiki/Privacy_Policy

12.5.7 Microsoft Azure

This website is hosted externally. The personal data collected on this website is stored on the servers of the hoster(s). This may include, but is not limited to, IP addresses, contact requests, meta and communication data, contractual data, contact details, names, website accesses and other data generated via a website.

External hosting is carried out for the purpose of contract fulfillment vis-à-vis our potential and existing customers (Art. 6 para. 1 lit. b DSGVO) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f DSGVO). Insofar as a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) as defined by the TTDSG. The consent can be revoked at any time.

Our hoster(s) will only process your data to the extent necessary to fulfill their service obligations and follow our instructions regarding this data.

We use the following hoster(s):

Microsoft Ireland Operations Ltd.

for the attention of: Data Protection

Carmenhall Road

Sandyford, Dublin 18, Ireland

12.5.8 Mailjet SAS

On our website we use the services of the cloud communications platform Mailjet SAS 4, rue Jules Lefebvre, 75009 Paris, France. Mailjet is a service that organizes and analyzes newsletter delivery. The data you enter for the purpose of receiving newsletters is stored on Mailjet's servers in the EU.

Our newsletters sent with Mailjet allow us to analyze the behavior of newsletter recipients. Among other things, we can analyze how many recipients have opened the newsletter message and how often which link in the newsletter was clicked. With the help of so-called conversion tracking, it can also be analyzed whether a predefined action (e.g. purchase of a product on our website) has taken place after clicking on the link in the newsletter. For more information on data analysis by Mailjet newsletters, please visit: mailjet.com/function/tracking-tools.

Mailjet also allows us to subdivide newsletter recipients based on various categories ("segmentation"). In doing so, newsletter recipients can be subdivided according to the data provided during registration. In this way, the newsletters can be better adapted to the respective target groups.

We also use mailjet to send automatic Email notifications to users that receive a chat message, comment on a project and more. You can find the full list in your email settings: https://climateconnect.earth/settings

For detailed information on Mailjet's functions, please refer to the following link: mailjet.com/function.

The data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke this consent at any time by unsubscribing from the newsletter and email notifications. The legality of the data processing operations already carried out remains unaffected by the revocation.

If you do not want any analysis by Mailjet, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in each newsletter message.

The data you provide for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers as well as from Mailjet's servers after you unsubscribe from the newsletter. Data stored by us for other purposes (e.g. e-mail addresses for the member area) remain unaffected by this.

For more details, please refer to Mailjet's "Security and Privacy" information at mailjet.com/security-privacy-policy and Mailjet's privacy policy at mailjet.com/privacy-policy.

13. Technical security measures

For security reasons and to protect the transmission of confidential information that you send to us as the website provider, we use SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from http:// to https:// and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

14. CHANGES TO OUR PRIVACY POLICY

We may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and you should review this page periodically. We will update the ‘last modified’ date at the bottom of this page when we post changes to this Privacy Policy. If you object to any changes, you may close your account. Continuing to use our Service after we publish changes to this Privacy Policy means that you have read and understood the changes.

Effective date: 22.02.2023