Executive Statement

At, we know that people care about their privacy — so do we. That’s why we have established a comprehensive privacy program, including a global privacy office and a privacy officer, designed to help us respect and protect privacy rights. To protect your privacy, will ensure all personal data is handled in a secure way and used only as outlined in the sections below. This privacy policy informs you what personal data we collect, how we use it and the measures we take to keep it safe. This policy is our commitment to privacy and includes provisions on the processing of personal data related to clients, consumers, citizens and employees.

This privacy policy applies to all subsidiaries, business units and personal data processing activities under the responsibility of All business units are accountable for ensuring that personal data is protected in all processes across its entire life cycle, keeping privacy measures top of mind. All of our employees are responsible for compliance with this policy.

Privacy Officer

Our CTO is appointed as our Privacy Office (PO) to monitor adherence to this privacy policy. If necessary, the PO will be supported by internal representatives, who are responsible on the PO’s behalf for ensuring privacy in the respective entities. They will inform the PO in case of complaints and coordinate breach response procedures, including representation to relevant authorities.

The representatives will abide by the findings of the PO. The respective management within is obligated to support the PO and the representatives in carrying out their duties.

All business stakeholders will collaborate with the PO or a representative and will assist business units (for example, legal, internal audit and human resources) on privacy matters.


This policy applies to all personal data processed by all employees, contractors and partners doing business on behalf of, as well as all legal entities/all subsidiaries of This policy excludes joint ventures where there is less than a 50% share by will adhere to privacy laws in all jurisdictions where it operates. Any mandatory registration provisions that may exist according to legal requirements must be observed. In case of uncertainty, leaders of legal entities/subsidiaries of and stakeholders must consult the PO and/or general counsel.

Collection of personal data by — and the disclosure to — governmental institutions and authorities will be carried out only on the basis of specific legal provisions. In all cases, this privacy policy imposes those restrictions that are necessary to meet the legal requirements of the respective laws.

Logging Practices’s web servers automatically record the Internet Protocol (IP) addresses of visitors. The IP address is a unique number assigned to every computer on the internet. Generally, an IP address changes each time you connect to the internet (it is a “dynamic” address). Note, however, that if you have a broadband connection, depending on your individual circumstance, the IP address that we collect may contain information that could be deemed identifiable. This is because, with some broadband connections, your IP address doesn’t change (it is “static”) and could be associated with your personal computer.

As well as recording the IP addresses of users, may also keep track of sites that users visited immediately prior to visiting’s website and the search terms they used to find it. The web server may keep track of the pages visited on’s website, the amount of time spent on those pages, the types of searches done on them, and products looked at. Your searches remain confidential and anonymous. uses this information only for statistical purposes, to find out which pages users find most useful and to improve the website. servers may also capture and store information that your browser transmits. This could include:

  • Browser type/version/plug-ins used or security levels
  • Operating system used
  • Media Access Control (MAC) address
  • Screen resolution
  • Date and time of the server request
  • Location-related data (such as the geographic location of the IP address)
  • Volume of data transferred
  • Access status (“file transferred,” “file not found” and so on)

This data will be used to generate statistics that help us to further optimize our websites to meet your individual needs.  We will not deduce personal information from this data. Depending on the selection of privacy settings upon visiting’s website, additional personal data processing may take place following your preferences.


Cookies are small text files that are placed on your computer by websites to track your individual movements on that website over time.

At, we use the following categories of cookies:

  • Essential cookies: These are used to authenticate you, prevent fraud and provide you with the services that you have requested.
  • Functional cookies: These are used to remember you and recall your settings or preferences (such as language) when you return to our website. These cookies are not used to track you when you visit other websites.

Cookies used by may be session-based or persistent. Session-based cookies last only for the duration of a user’s session, while a persistent cookie remains on the user’s hard drive. A persistent cookie can help us recognize you when you return to our website and recall your settings or preferences.

If you do not want a cookie placed on your computer as a result of using a website, you can disable cookies altogether by modifying the preferences section of your web browser. Note that if you do so, some aspects of websites may be unavailable to you. If you choose to accept cookies on your hard drive, but wish to be informed of their appearance, you may turn on a warning prompt by modifying the cookie-warning section also located in the preferences section of your web browser.

External Links Disclaimer

Some of’s websites link to other sites created and maintained by other public- and/or private-sector organizations. provides these links solely for your information and convenience. When you transfer to an outside website, you are leaving the domain, and’s information management policies no longer apply. encourages you to read the privacy statement of each external website that you visit before you provide any personal data.

Communicating With Us

If you choose to contact staff using an email address, a discussion forum, a blog, a text message or other electronic communication method, or if you choose to complete an online form provided on the website (e.g., a customer feedback form), we may ask you to provide your name, email address or other personal data.

The purpose of collecting this information is to allow staff to respond to your inquiry or to evaluate individual web services. Only authorized staff will have access to the information provided, and the information will be used only for the purpose it was intended. Completed surveys are sent to staff anonymously. We will ask you to provide us only with a method of contacting you (email, phone or mailing address) if you wish to be included in future surveys or to have us respond to you.

Security implements commercially reasonable technical and organizational security controls to protect your personal data against theft, loss or misuse. Your data will be stored in a secure operating environment that is not accessible without authorization. applies mitigation measures following periodic risk assessments to ensure an adequate level of protection of your personal data.

Please note for business continuity and disaster recovery purposes, may store data in a location outside the jurisdiction(s) in which we normally operate. In such scenarios, we will implement all commercially reasonable measures to protect your personal data against theft, loss or misuse.

Personal Data About Minors and Children does not knowingly collect data from or about children under 13. If we learn that we have collected personal information from a child under 13 we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 please contact us at

Applicable Law

This privacy policy is governed and will be interpreted in accordance with the laws of the United States of America.

If you use our services and reside outside the United States of America, your information will be transferred to the United States of America and will be processed and stored there under United States of America privacy standards. By using our services and providing information to us, you consent to such transfer to the United States of America and processing there.

What Personal Data We Use may use any of the following pieces of personal data in line with the use purposes explained below:

  • Your name and contact details
  • Communication details
  • Authentication data
  • Online profile data
  • Online activity/profile usage
  • Purchasing information
  • Payment methods and history
  • Information about the device(s) you use
  • Information about the service usage
  • Support information
  • Cookies
  • Social media profile plug-in information
  • Date of birth
  • Your credit card information
  • Subscription preferences
  • Location information and GPS data
  • Any other information you upload or provide us with

How We Use Personal Data uses the information collected to provide a safe, efficient and customized experience. Here are some of the details on how we do that:

  • To manage the service: We use the information we collect to provide our services and features to you, to measure and improve those services and features, and to provide you with customer support. We use the information to prevent potentially illegal activities and to enforce our terms and conditions. We also use a variety of technological systems to detect and address anomalous activity and to screen content to prevent abuse, such as spam. These efforts may, on occasion, result in a temporary or permanent suspension or termination of some functions for some users.
  • To contact you: We may contact you with service-related announcements from time to time. You may opt out of all communications except for essential updates.

Who Else May Process Personal Data may share the information collected with third parties to provide a safe, efficient and customized experience. Here are some of the details on how we do that:

  • To provide services: may share your personal data with agents, contractors or partners of in connection with services that these individuals or entities perform for or with These agents, contractors or partners are restricted from using this data in any way other than to provide services for, or for the collaboration in which they and are engaged. For example, some of our products are developed and marketed through joint agreements with other companies. We may, for example, provide your information to agents, contractors or partners for hosting our databases, data processing or mailing you information that you requested. More details about this can be found in our Data Protection Agreement.
  • To make a payment: When you enter into transactions with others or make payments on’s website, we will share transaction information with those third parties necessary to complete the transaction. We will require those third parties to respect your privacy and to adequately protect your information.
  • To respond to legal requests and prevent harm: reserves the right to share your information to respond to duly authorized information requests of governmental authorities or where required by law. In exceptionally rare circumstances where national, state or company security is at issue (such as terrorist attacks), reserves the right to share our entire database of visitors and customers with appropriate governmental authorities.

We never sell your personal data to third parties, such as marketers, without your consent. We do not provide any personal data to “people finder,” “public directory” or “white pages” sites.

If our company is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. The promises in this privacy policy will apply to your information as transferred to the new entity.

Your Right to Access Personal Data

In addition to the information that is available on’s website, you have the right to access the personal data that holds about you, all subject to the exemptions as contained in applicable laws and regulations. If you request the data, then will assist you. Your identity will need to be confirmed before you are provided with access to personal data. Generally, does not charge for providing information, but if the request requires significant staff time, reserves the right to charge a fee for such requests. More details about this can be found in our Data Protection Agreement.

We ask that you put your request in writing. Use the Contact Us form here. If you choose to write a letter rather than fill out a form, please include the following:

  • Your full mailing address 
  • Your daytime telephone number
  • Names of specific files or types of records to which you request access, including specific dates of those records, where possible

Please provide as much detail as possible.

All formal access requests will be directed to the privacy officer, who will then review each request to determine whether will disclose the requested information. The privacy officer will also receive and address all privacy complaints that receives. The privacy officer can be reached at the address listed below.

You will be notified if access to the records you have requested is granted or denied, and which exemptions apply.

Your Right to Correct or Amend Personal Data

If you believe there is a mistake in your personal data, you have a right to ask for the information to be corrected. We may ask you to provide documentation to show where’s files are incorrect. We will amend the erroneous data within 1 month and will notify you once the correction you have requested has been completed.  We will notify any person or organization to which your personal data was disclosed within the year before you requested correction and advise them about the correction or statement of disagreement.

Your Right to Take Personal Data With You (Portability)

You may obtain and reuse the personal data held by for your own purposes across different services. allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. This right applies to your personal data held by where the processing was automated and used taking into account our service provision within the contract you have with or where such processing was based on the consent you gave for it.

Your Right to Be Erased or Forgotten does not store personal data without a predefined and documented purpose. We follow laws that require us to delete personal data if the reason for its collection and storage no longer exists. We believe this fulfills the requirements of the privacy principle of “the right to be forgotten.”

Where the personal data that holds is based on the consent you provided, and you wish to be removed from our systems prior to the retention period indicated in the “How Long We Use Personal Data” section, please contact our privacy officer at

Enforcement and Audit uses a self-assessment approach to ensure compliance with this privacy policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and in conformity with privacy principles.


We encourage anyone interested to raise any concerns using the contact information provided in our “Contact Us” page. We will investigate and attempt to resolve any complaints and disputes regarding the use and disclosure of personal data.

Automated Decisions

Certain countries provide restrictions relating to automated decisions that affect individuals. Such automated decisions that affect individuals are decisions that are the result of the automated processing of personal data and that have a legal effect on the individual, or affect him or her negatively. does not render any automated decisions that affect individuals.

Review and Ratification

We may occasionally update or modify this privacy policy. To ensure that the importance of this privacy policy is communicated uniformly throughout the enterprise, all members of’s leadership team will review, update and ratify this privacy policy at least annually.

For material changes to this privacy policy, we will notify you by placing a prominent notice on the homepage of our website or, if legally required, by directly sending you a notification. We encourage you to periodically review this privacy policy to stay informed about how we are helping to protect the personal data we collect. Your continued use of the service constitutes your agreement to this privacy policy and any updates.



“Personal data” (or “personal information”) means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly — in particular, by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.

“Special Categories of Personal Data” pertains to personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and the processing of data concerning health or sex life.

“Sensitive personal data” either indicates “special categories” (see above), or is personal data of which the sensitivity level has been assessed and classified, indicating potential severe impact on an individual when confidentiality of such data is breached.

“Anonymization” is the deletion or changing of personal data in such a way that it can no longer be assigned to a certain or ascertainable individual or only with a disproportionately high effort in terms of time, cost and work.

“Pseudonymization” is the replacement of an individual’s name and other identifiable characteristics with a label to prevent identification of the individual by unauthorized parties or to render such identification substantially difficult. Pseudonymization techniques include certain levels of masking, redaction, tokenization and/or encryption of personal data.

“Consent” is any freely given, specific and transparently, well-informed indication of the will of the individual, whereby the individual agrees that his or her personal data may be processed. Particular requirements about consent can arise from the respective national laws. Where possible, consent is obtained in an explicit manner (unambiguously).

Changes to our privacy policy keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on April 15, 2024.

Complaints and Communication (“Contact Us”)’s website and all its gateways are governed by the policies and principles outlined above. relating to your privacy, contact:
Todd Chaplin
2997 Cobb Parkway SE
Unit 725567
Atlanta, GA  31139-2702