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Privacy policy

1. What is the purpose of this Privacy Policy?

Neuromobil GmbH (hereinafter also referred to as “we” or “us”) collects and processes personal data relating to you or to other individuals (so-called “third parties”). In this Privacy Policy, the term “data” is used synonymously with “personal data.”

“Personal data” means any information relating to an identified or identifiable person, i.e., data that allows conclusions to be drawn about a person’s identity either on its own or in combination with additional information. “Sensitive personal data” refers to a special category of personal data that is subject to enhanced protection under applicable data protection law. Sensitive personal data includes, for example, information revealing racial or ethnic origin, health data, religious or philosophical beliefs, biometric data for identification purposes, and trade union membership. In section 3, you will find details on the types of data we process under this Privacy Policy. The term “processing” covers any handling of personal data, such as collecting, storing, using, modifying, disclosing, or deleting it.

This Privacy Policy describes what we do with your data when you use www.neuromobil.ch (hereinafter referred to as the “Website”).

If you provide us with data relating to other persons (e.g., family members, colleagues, etc.), we assume that you are authorized to do so and that such data is accurate. By submitting such data, you confirm this authorization. Please also ensure that the individuals concerned have been informed about this Privacy Policy.

This Website is intended exclusively for individuals residing in Switzerland. This Privacy Policy has been drafted to comply with the requirements of the revised Swiss Federal Act on Data Protection (“revFADP”).

2. Who is responsible for processing your data?

Neuromobil GmbH, 5000 Aarau (hereinafter “Neuromobil”), is responsible under data protection law for the data processing activities described in this Privacy Policy, unless otherwise communicated in a specific case.

You can contact us regarding any data protection concerns or to exercise your rights pursuant to section 11 at the following address:
Neuromobil GmbH, Neurophysiological Diagnostics, Dufourstrasse 8, CH-5000 Aarau, heimgartner@neuromobil.ch

We have also designated the following additional entity:

Data Protection Advisor pursuant to Art. 10 revFADP
Neuromobil GmbH, Samuel Heimgartner, Dufourstrasse 8, CH-5000 Aarau, heimgartner@neuromobil.ch

3. What data do we process?

We process various categories of data about you. The most important categories are as follows:

Technical data
When you use our Website, we collect the IP address of your device and other technical data in order to ensure the functionality and security of this service. These data also include logs that record the use of our systems. To ensure the proper functioning of these services, we may also assign an individual code to you or your device (e.g., in the form of a cookie, see section 11). Technical data alone generally do not allow us to identify you. However, in the context of user accounts, registrations, access controls, or the execution of contracts, such data may be linked to other data categories (and thus potentially to your identity). Information on the privacy policies of our provider Cyon can be found here.

Technical data include, for example, the IP address and information about the operating system of your device, the date, region, and time of use, and the type of browser you use to access our digital services. This information can help us deliver the correct formatting of the Website or display a region-specific version. While your IP address allows us to determine your provider (and thus your region), we generally cannot identify who you are. This changes, for example, if you create a user account, as personal data can then be linked to technical data (e.g., we may see which browser you use to access your account on our Website). Technical data also include logs that are generated in our systems (e.g., records of user logins to our Website).

Registration data
Certain services, such as competitions and services (e.g., login areas of our Website, newsletter subscriptions, etc.), may only be used with a user account or registration, either directly with us or via external login providers. In such cases, you must provide us with certain data, and we collect information about your use of the service.

Registration data include the information you provide when creating an account on our Website (e.g., username, password, name, email address). You must also register if you wish to subscribe to our newsletter.

Communication data
When you contact us via contact form, email, telephone, chat, or other means of communication, we record the data exchanged between you and us, including your contact details and metadata of the communication.

Communication data include your name and contact details, the method, place, and time of communication, and usually also the content (i.e., the text of emails, chats, etc.). These data may also contain information about third parties.

Master data
Master data refers to the core information that we need, in addition to contract data, to manage our contractual and other business relationships or for marketing and advertising purposes, such as name, contact details, information about your role and function, bank account details, date of birth, customer history, powers of attorney, signing authorities, and declarations of consent. We process your master data if you are a customer or other business contact, or if you act on behalf of such a person (e.g., as a contact person for a business partner), or because we wish to approach you for our own purposes or for those of a contractual partner (e.g., in the context of marketing and advertising, invitations to events, vouchers, newsletters, etc.).

We receive master data directly from you (e.g., during a purchase or registration), from entities you work for, or from third parties such as contractual partners, associations, address brokers, and from publicly accessible sources such as registers or the Internet (websites, social media, etc.). We generally retain these data for 10 years after the last interaction with you, but at least until the end of a contractual relationship. This retention period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. For marketing and advertising contacts only, the retention period is usually much shorter, generally no more than 2 years after the last contact.

Behavioral and preference data
Depending on our relationship with you, we seek to understand your needs and better tailor our products, services, and offers to you. For this purpose, we collect and use data about your behavior and preferences. We do so by analyzing information about your activities within our scope of services and may also supplement this information with data from third parties – including publicly available sources. Based on this, we may calculate the likelihood that you will use certain services or behave in a certain way.

Some of these data are already known to us (e.g., when you use our services), while others are collected by recording your behavior (e.g., how you navigate our Website). We anonymize or delete these data once they are no longer relevant for the intended purposes, which may range from 2–3 weeks (for movement profiles) up to 24 months (for product and service preferences). This period may be longer if necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. How tracking on our Website works is described in section 11.

Preference data provide us with insights into your needs, which products or services may be of interest to you, or when and how you are likely to respond to our messages. We obtain such information from analyzing existing data (e.g., behavioral data) to get to know you better, improve our advice and offerings, and enhance our services overall. To improve the quality of our analyses, we may combine these data with information from third parties such as address brokers, authorities, and publicly available sources like the Internet, e.g., data about household size, income bracket, purchasing power, shopping habits, contact details of relatives, and anonymized information from statistical offices.

Behavioral and preference data may be analyzed on a personal basis (e.g., to display personalized advertising to you) or on a non-personal basis (e.g., for market research or product development). Behavioral and preference data may also be combined with other data (e.g., movement data may be used in a health protection plan for contact tracing).

Much of this data is provided directly by you (e.g., via forms, communications with us, in connection with contracts, or through use of the Website). You are not obliged to do so, except in specific cases such as compliance with mandatory protection concepts (legal requirements). The processing of technical data is unavoidable when using our Website. However, with respect to behavioral and preference data, you generally have the option to object or to withhold consent.

Where permissible, we also obtain data from publicly accessible sources (e.g., debt registers, land registers, commercial registers, media, or the Internet including social media) or receive data from other companies within our group, from authorities, and from other third parties (e.g., credit agencies, address brokers, associations, contractual partners, internet analytics services, etc.).

4. For what purposes do we process your data?

We process your data for purposes related to communication with you, in particular to respond to inquiries, to assert your rights, and to contact you in case of follow-up questions. For this purpose, we primarily use communication data and master data, and in connection with services and offerings you use, also registration data. We retain these data to document our communication with you, for training purposes, quality assurance, and for follow-up inquiries.

We also process data for marketing purposes and relationship management, e.g., to send our customers and other contractual partners personalized advertising about our own products and services as well as those of third parties (e.g., advertising partners). This may occur in the form of newsletters and other regular contacts (electronically, by post, by telephone), through other channels for which we have your contact information, as well as in the context of individual marketing campaigns (e.g., events, competitions, etc.), which may also include free services (e.g., invitations, vouchers, etc.). You may object to such contacts at any time or refuse or withdraw your consent to being contacted for advertising purposes. With your consent, we may also tailor our online advertising more specifically to you.

We further process your data for market research, to improve our services and operations, and for product development.

We strive to continuously improve our products and services (including our Website) and to respond quickly to changing needs. For this reason, we analyze, for example, how you navigate our Website, which products are used by which groups of people and in what manner, and how new products and services can be designed. This provides us with insights into the market acceptance of existing products and the market potential of new ones. For these purposes, we primarily process master, behavioral, and preference data, but also communication data and information from customer surveys, polls, studies, as well as other information, e.g., from the media, social media, the Internet, and other public sources. Where possible, we use pseudonymized or anonymized data for these purposes. We may also use media monitoring services or conduct our own media monitoring and in doing so process personal data in order to conduct media work or to understand and respond to current developments and trends.

5. On what basis do we process your data?

Where we ask for your consent for certain types of processing (e.g., for the processing of sensitive personal data, for marketing mailings, for the creation of personalized movement profiles, or for advertising control and behavioral analysis on the Website), we will inform you separately about the specific purposes of the processing. You may withdraw your consent at any time with effect for the future, either in writing (by post) or—unless otherwise specified or agreed—by email; our contact details are set out in section 2. For the withdrawal of consent in connection with online tracking, see section 11. If you have a user account, you may also be able to withdraw your consent or contact us directly via the relevant Website or service. Once we have received notification of your withdrawal of consent, we will cease processing your data for the purposes to which you originally consented, unless another legal basis applies. Withdrawal of consent does not affect the lawfulness of processing carried out based on your consent prior to its withdrawal.

Where we do not request your consent for processing, we process your personal data on the basis that such processing is necessary for the initiation or performance of a contract with you (or the entity you represent), or because we or third parties have a legitimate interest in doing so. Such legitimate interests include, in particular, pursuing the purposes and objectives described in section 4 above and taking the related measures. Our legitimate interests also include compliance with legal obligations, insofar as this is not already recognized as a separate legal basis under applicable data protection law (e.g., under the GDPR in the EEA and Switzerland). Legitimate interests further include the marketing of our products and services, the interest in better understanding our markets, and the safe, efficient, and further development of our business, including our operations.

If we receive sensitive data (e.g., health data, information on political, religious, or philosophical beliefs, or biometric data for identification purposes), we may also process such data on other legal grounds—for example, where processing is necessary in connection with disputes or for the establishment, exercise, or defense of legal claims. In individual cases, other legal grounds may apply, which we will inform you of separately if required.

6. To whom do we disclose your data?

In connection with our contracts, the Website, our services and products, our legal obligations, or otherwise in order to safeguard our legitimate interests and for the other purposes set out in section 4, we also disclose your personal data to third parties, in particular to the following categories of recipients:

Service providers
We work with service providers in Switzerland and abroad who process data about you on our behalf or in joint responsibility with us, or who receive data about you from us in their own responsibility (e.g., IT providers, advertising service providers, login providers). For service providers engaged for the Website, see section 11.

To provide our products and services efficiently and to focus on our core competencies, we obtain services from third parties in numerous areas. These services include, for example, IT services, the dispatch of information, marketing, sales, communication or printing services, and address verification (e.g., updating address records in the event of relocation). We disclose to these service providers the data necessary for their services, which may include your personal data. Our service providers may also process data on how their services are used, and other data arising in the course of providing their services, as independent controllers for their own legitimate interests (e.g., for statistical evaluations or billing). Service providers inform about their independent data processing in their own privacy policies.

Contractual partners, including customers
This primarily refers to our customers (e.g., service recipients) and other contractual partners, since such data disclosures result from these contracts. For example, they may receive registration data on issued and redeemed vouchers, invitations, etc. If you yourself act for such a contractual partner, we may also disclose data about you in that context. Recipients also include contractual partners with whom we cooperate or who advertise on our behalf, and to whom we therefore disclose data about you for analysis and marketing purposes (these may again be service recipients, but also sponsors and online advertising providers, for example). We require such partners to only send you advertising or display it based on your data if you have consented (for online activities, see section 11).

If you act as an employee for a company with which we have concluded a contract, the performance of this contract may result in us informing the company, for example, how you have used our service. Cooperation and advertising partners receive selected master, contract, behavioral and preference data from us so that they can, on the one hand, carry out non-personal evaluations in their area (e.g., regarding the number of our customers who have viewed their advertising) and, on the other hand, use the data for advertising purposes (including targeted outreach to you). For example, advertising partners should be able to communicate with suitable other customers of ours and send them advertising.

Authorities
We may disclose personal data to offices, courts, and other authorities in Switzerland and abroad if we are legally obliged or entitled to do so or if this appears necessary to protect our interests. Authorities process data about you received from us under their own responsibility.

Typical cases include criminal investigations, police measures (e.g., health protection concepts, combating violence, etc.), regulatory requirements and investigations, court proceedings, reporting obligations, pre-litigation and extrajudicial proceedings, as well as statutory information and cooperation duties. Data disclosure may also occur if we seek information from public authorities, for example, to substantiate a legitimate interest or because we must specify about whom we require information (e.g., from a register).

Other parties
This includes cases where the involvement of third parties arises from the purposes described in section 4, e.g., service recipients, media, and associations in which we participate, or where you are part of one of our publications.

Other recipients may include alternative delivery recipients specified by you, third-party payment recipients, other third parties in the context of representation relationships (e.g., if we send your data to your lawyer or bank), or persons involved in official or court proceedings. If we cooperate with the media and provide them with material (e.g., photos), you may also be affected. The same applies to the publication of content (e.g., photos, interviews, quotations, etc.) on our Website or in other publications. In the context of corporate development, we may sell or acquire businesses, parts of businesses, assets, or companies, or enter into partnerships, which may also involve the disclosure of data (including yours, e.g., as a customer or supplier or as a supplier’s representative) to persons involved in such transactions. In the course of communication with competitors, industry organizations, associations, and other bodies, data relating to you may also be exchanged.

All these categories of recipients may in turn involve third parties, so that your data may also become accessible to them. We can restrict processing by certain third parties (e.g., IT providers), but not by others (e.g., authorities, banks, etc.).

We also reserve the right to disclose data even if it is confidential (unless we have expressly agreed with you not to disclose such data to certain third parties, unless we are legally obliged to do so). Notwithstanding this, your data will remain subject to adequate protection even after disclosure within Switzerland and the rest of Europe. For disclosures to other countries, see section 8. If you do not wish certain data to be disclosed, please let us know so we can assess whether and to what extent we can accommodate you (section 2).

In many cases, disclosure of confidential data is also necessary in order to perform contracts or otherwise provide services. Confidentiality agreements generally do not exclude such disclosures, nor do disclosures to service providers. Depending on the sensitivity of the data and other circumstances, we nevertheless ensure that such third parties handle the data appropriately. We cannot comply with an objection to disclosure where the relevant data disclosure is necessary for our operations.

We also enable certain third parties, both on our Website and at our events, to collect personal data about you themselves (e.g., press photographers, providers of tools embedded on our Website, etc.). To the extent that we are not materially involved in such data collection, these third parties are solely responsible. For any concerns and to exercise your data protection rights, please contact these third parties directly. See section 11 with respect to the Website.

7. Is your personal data also transferred abroad?

As explained in section 6, we also disclose data to other parties. These are not located exclusively in Switzerland. Your data may therefore be processed both in Europe and outside Europe; in exceptional cases, however, in any country worldwide.

If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with the applicable data protection standards (for this we use the revised Standard Contractual Clauses of the European Commission, available here), unless the recipient is already subject to a legally recognized framework ensuring data protection or we can rely on a statutory exemption. An exemption may apply in particular in the case of legal proceedings abroad, but also where there is an overriding public interest, where disclosure is necessary for the performance of a contract, where you have consented, or where the data in question has been generally made accessible by you and you have not objected to its processing.

Many countries outside Switzerland and the EU/EEA currently do not have laws that ensure an adequate level of data protection from the perspective of the FADP. With the contractual safeguards mentioned, this weaker or absent statutory protection can be partially compensated. However, contractual safeguards cannot eliminate all risks (particularly of government access abroad). You should be aware of these residual risks, even though the risk may be low in individual cases and we take additional measures (e.g., pseudonymization or anonymization) to minimize it.

Please also note that data exchanged over the Internet is often routed via third countries. Your data may therefore be transferred abroad even when the sender and the recipient are located in the same country.

8. How long do we process your data?

We process your data for as long as required by our processing purposes, statutory retention periods, and our legitimate interests in processing for documentation and evidence purposes, or where storage is technically necessary. Further details on the respective retention and processing periods can be found for each data category in section 3 and for cookie categories in section 11. Where no legal or contractual obligations prevent us from doing so, we delete or anonymize your data after the retention or processing period has expired, in line with our standard procedures.

9. How do we protect your data?

We implement appropriate security measures to maintain the confidentiality, integrity, and availability of your personal data, to protect it against unauthorized or unlawful processing, and to mitigate the risks of loss, accidental alteration, unintended disclosure, or unauthorized access.

10. What rights do you have?

Applicable data protection law grants you, under certain circumstances, the right to object to the processing of your data, particularly in relation to processing for direct marketing purposes, profiling carried out for direct marketing, and other legitimate interests in processing.

To give you greater control over the processing of your personal data, you may also have the following rights in connection with our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and what data we process about you;
  • The right to have us correct data if it is inaccurate;
  • The right to request the deletion of data;
  • The right to request the release of certain personal data in a commonly used electronic format or its transfer to another controller;
  • The right to withdraw consent, insofar as our processing is based on your consent;
  • The right to receive further information, upon request, that is necessary for the exercise of these rights.

If you wish to exercise the above rights against us (or against one of our group companies), please contact us in writing, in person at our premises, or—unless otherwise specified or agreed—by email; our contact details can be found in Section 2. To prevent abuse, we must be able to identify you (e.g., by means of a copy of your ID, where no other method is possible).

You also have these rights against other parties who work with us as independent controllers—please contact them directly if you wish to exercise rights in relation to their processing. Information about our key cooperation partners and service providers can be found in Section 6, and further information in Section 11.

Please note that these rights may be subject to conditions, exceptions, or restrictions under applicable data protection law (e.g., to protect third parties or trade secrets). We will inform you accordingly where applicable.

If you do not agree with how we handle your rights or data protection, please let us or our Data Protection Officer (see Section 2) know. You also have the right to lodge a complaint with the data protection supervisory authority.

11. Do we use online tracking and online advertising technologies?

On our website, we use various technologies that enable us and third parties engaged by us to recognize you during your use and, in some cases, track you across multiple visits. In this section, we inform you about this.

Essentially, it is about distinguishing your visits (through your system) from those of other users so that we can ensure the functionality of the website, perform evaluations, and provide personalization. We do not intend to identify you personally, although this is possible if we or third parties engaged by us combine such data with registration details. Even without registration data, the technologies used are designed so that you are recognized as an individual visitor each time you access a page—for example, by our server (or third-party servers) assigning a specific identifier to you or your browser (so-called “cookie”).

Other techniques may also be used to recognize you with varying degrees of probability (i.e., to distinguish you from other users), such as “fingerprinting.” Fingerprinting combines your IP address, the browser you use, screen resolution, language settings, and other information that your system transmits to any server, thereby creating a more or less unique “fingerprint.” This makes it possible to avoid using cookies.

Whenever you access a server (e.g., when using a website or app, or when a visible or invisible image is embedded in an email), your visits may be “tracked.” If we integrate offerings from an advertising partner or analytics tool provider into our website, they may track you in the same way, even if you cannot be identified in a specific case.

We use such technologies on our website and also allow certain third parties to do so. You can configure your browser to block, disguise, or delete certain cookies or alternative technologies. You can also extend your browser with software that blocks tracking by certain third parties. Further information can be found in your browser’s help pages (usually under “Privacy”) or on the websites of the third parties listed below.

The following types of cookies (including technologies with similar functionalities, such as fingerprinting) are distinguished:

Necessary cookies: Some cookies are required for the website to function at all or for certain features to work. For example, they ensure that you can navigate between pages without losing information entered into a form. They also ensure that you remain logged in. These cookies exist only temporarily (“session cookies”). If you block them, the website may not work properly. Other cookies are necessary for the server to remember your choices or inputs across a session (i.e., a website visit) if you use such a feature (e.g., selected language, consent given, automatic login function). These cookies may have an expiration date of up to 24 months.

Performance cookies: To optimize our website and related offerings and better adapt them to user needs, we use cookies to record and analyze the use of our website, potentially beyond a single session. We do this through the use of third-party analytics services. These are listed below. Performance cookies also have an expiration date of up to 24 months. Details can be found on the websites of the third-party providers.

Marketing cookies: We and our advertising partners are interested in targeting advertising to specific audiences, i.e., to display ads primarily to those we want to reach. Our advertising partners are listed below. For this purpose, we and our advertising partners—if you consent—also use cookies that can capture accessed content or concluded contracts. This allows us and our advertising partners to display advertising that we believe may interest you—on our website, as well as on other websites that display advertising from us or our partners. Depending on the situation, these cookies have an expiration period ranging from a few days to 14 months. If you consent to the use of such cookies, you will be shown targeted advertising. If you do not consent, you will not see fewer ads, but simply different ads.

In addition to marketing cookies, we use further techniques to manage online advertising on other websites, thereby reducing scatter losses. For example, we may transmit the email addresses of our users, customers, and other individuals to whom we want to show advertising to operators of advertising platforms (e.g., social media). If these individuals are registered there with the same email address (which the platforms determine by matching), the operators will display our advertising specifically to these individuals. The operators do not receive personal email addresses of previously unknown persons. However, in the case of known email addresses, they learn that these individuals are connected to us and which content they have accessed.

Google Analytics
Google Ireland (based in Ireland) provides the “Google Analytics” service and acts as our processor. For this purpose, Google Ireland relies on Google LLC (based in the USA) as its processor (together “Google”). Google uses performance cookies (see above) to track visitor behavior on our website (duration, frequency of page visits, geographical origin of access, etc.) and creates reports for us on this basis about the use of our website.

We have configured the service so that visitors’ IP addresses are truncated by Google within Europe before being forwarded to the USA, preventing them from being traced. We have also disabled the “data sharing” and “signals” settings. Although we can assume that the information we share with Google does not constitute personal data for Google, it is possible that Google may draw conclusions about the identity of visitors from such data, create personal profiles, and link these data with the Google accounts of those individuals. If you consent to the use of Google Analytics, you explicitly agree to such processing, which also includes the transfer of personal data (in particular, usage data of the website and app, device information, and individual IDs) to the USA and other countries.

Information on Google Analytics data protection can be found here: Google Analytics Privacy and, if you have a Google account, further details on Google’s processing can be found here: Google Privacy Policy & Terms.

12. What data do we process on our social media pages?

We may operate pages and other online presences (such as “fan pages,” “channels,” or “profiles”) on social networks and other third-party platforms, where we collect the data described in Section 3 and below about you. We receive this data from you and the platforms when you interact with us via our online presence (e.g., when you communicate with us, comment on our content, or visit our page). At the same time, the platforms analyze your use of our online presences and link this data with other information they already hold about you (e.g., regarding your behavior and preferences). They also process this data for their own purposes under their own responsibility, in particular for marketing and market research purposes (e.g., to personalize advertising) and to manage their platforms (e.g., deciding which content to display to you).

We receive data about you when you communicate with us via our online presences or when you view our content, visit our pages, or are active on the relevant platforms (e.g., by posting content or leaving comments). These platforms also collect from you or about you, among other things, technical data, registration data, communication data, behavioral data, and preference data (see the terms in Section 3). These platforms regularly analyze how you interact with us, how you use our online presences, our content, or other parts of the platform (what you view, comment on, “like,” share, etc.), and statistically evaluate this data while linking it with other information about you (e.g., age, gender, and other demographic information). In this way, they create profiles about you and statistics on the use of our online presences. They use this data and these profiles to display personalized advertising and other content on the platform, to manage the behavior of the platform, as well as for market and user research and to provide us and other parties with information about you and your use of our online presences. We may have limited control over the analyses the platforms perform regarding the use of our presences.

We process this data for the purposes described in Section 4, in particular for communication, for marketing purposes (including advertising on these platforms, see Section 11), and for market research. You can find the relevant legal bases in Section 5. Content you publish yourself (e.g., comments on an announcement) may be re-used by us (e.g., in our advertising on the platform or elsewhere). We or the platform operators may also delete or restrict content from or relating to you in accordance with the usage guidelines (e.g., inappropriate comments).

For more information on how the platform operators process your data, please refer to their privacy policies. There you will also find details on the countries where they process your data, what rights you have (access, deletion, etc.), and how you can exercise these rights or obtain further information.

We currently use the following platform:

  • LinkedIn
    We operate the page [www.linkedin.com/adresse]. The responsible entity for operating the platform for users in Europe is LinkedIn Ireland Unlimited Company, Dublin 2, Ireland. Their privacy policy can be found at: LinkedIn Privacy Policy. Within the framework of “Page Insights,” statistics are created about what visitors do on our page (e.g., commenting on posts, sharing content, etc.). This helps us understand how our page is used and how we can improve it. We only receive anonymous, aggregated data in this context.

Can this Privacy Policy be changed?

This Privacy Policy is not part of a contract with you. We may amend this Privacy Policy at any time. The version published on this website is the most current version.

Last updated: February 2025