Privacy Policy

This Privacy Policy (“Privacy Policy”) applies to the processing of personal data of users (“user” or “you”) by Bending Spoons S.p.A. (“we” or “us”), the parent company of Splice Video Editor S.r.l., when you use the Splice mobile application (“app”) or otherwise interact with us and this Privacy Policy is presented to you, in accordance with Regulation (EU) 2016/679 – General Data Protection Regulation (“GDPR”), the Italian Legislative Decree 196/2003 (as amended), and other applicable local laws, as amended or replaced (jointly, “Applicable Privacy Laws”).

If you are a California resident, please see Section 11 (Additional Information for California Consumers) below.

If you are using an app version older than iOS 14, you should refer to this version of the privacy policy.

1. Data Controller and Data Protection Officer

The Data Controller is Bending Spoons S.p.A., based in Corso Como 15, Milan, MI 20154 (Italy), VAT 08931860962. For any requests regarding the processing of your personal data, please email us at privacy@bendingspoons.com.

Our Data Protection Officer can be contacted by sending an email to dpo@bendingspoons.com for any requests relating to the processing of your personal data or this Privacy Policy.

2. Categories of Personal Data that We Collect, Purposes and Legal Bases for Our Processing

We process the following categories of personal data, for the purposes and on the legal bases indicated below. Please note that not all of the below information may be deemed personal data in your jurisdiction in all cases.

Purpose	Legal Basis	Categories of Processed Data
To enable you to use the app and to provide you with its functionalities, including: video editing tools (including AI-based features) create captions which allow you to convert audio of your project into text.	The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR).	Identifiers and internet and network activity information (such as IP address, device model, device type, OS version, device language, device name, country set in the device settings, information about your interactions with the app, and unique identifiers), and other information necessary to enable you to use the app. If the app needs to access your photo and video library, your music library, or your microphone recordings when you use the app, it requires your permission. However, all processing of this data occurs on your device, and we do not collect or have access to such data, except for data which will be strictly necessary to provide you with specific features (such as to create captions, to store your project on our cloud, to share your project with other users) or if you expressly give your consent for the specific purpose of fixing errors occurred during the export or the loading of your project.
To improve our products and services (for example, by conducting statistical analysis or other research activities to optimize our features and provide you with new ones).	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to improve our products and services. As for the collection of personal data by means of analytics tracking technologies, please see Section 12 (In-app Tracking Technologies).	Identification and contact information you provide us (such as name, age, social media handle, or email address, when requested), identifiers and internet and network activity information (such as IP address), and information collected or generated to improve the app’s functionalities (such as information about your interactions with the app, inferences we generate and other related information about your usage of the app).
To improve our photo-video editing features in Splice and in other photo-video editing apps provided by us and our subsidiary companies, and offer a better service for editing and enhancing your images (for example, by using your videos and images to train and validate our photo-video editor algorithms in Splice and in other similar mobile and web apps provided by us and our subsidiary companies, and by examining and labelling your images to improve the performance of our editing and enhancement features).	The legal basis for the processing is your consent (art. 6(1)(a) of the GDPR).	Images, videos and audio-recordings uploaded by you.
To ensure the quality of the services by analyzing, preventing or correcting failures and bugs, illicit use or misuse of the services.	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to ensure the quality and the smooth functioning of the service. When you submit an error report and decide to share the content of your project with us to improve the app, the legal basis is your consent (art. 6(1)(a) of the GDPR). We will collect and have access to the content of your project only if you give us your consent.	Identifiers, internet and network activity information (such as IP address), inferences we generate and other related information about your usage of the app, the audio voices and transcriptions used to create captions, and the content of your project, including the title of the project and all the videos, photos, audios, texts used to create it on Splice. If you give us your consent, the content of your project.
To comply with our legal obligations, including requests from public authorities.	The legal basis for the processing is compliance with legal obligations to which we are subject (art. 6(1)(c) of the GDPR).	Any information which may be required by law or under the instructions of public authorities.
To process and respond to customer support communications and to requests for information you may raise with us.	The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR).	Identification and contact information you provide us (such as name, email address) and the content of your communication or request.
To establish, exercise or defend our rights and those of our employees, and to carry out corporate transactions or operations (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions).	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to establish, exercise or defend our rights and to carry out corporate transactions or operations.	Any information necessary to ensure the performance of these purposes.
To analyze your usage information, including your preferences, interests and behaviors when you use our products and services to: Conduct surveys, statistical analysis or other research activities to improve our products and services. Maintain, optimize, and develop new features. Advertise our products and services towards more creators like you and reach out to inactive users with our ads. Measure the effectiveness of our campaigns and make our advertising more relevant.	The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR). The collection of personal data by means of profiling and third-party analytics tracking technologies is based on your consent (art. 122 of Italian Privacy Code). For more details, please see Section 12 (In-app Tracking Technologies).	Your identification and contact information (such as name, age or email address, when requested), identifiers and Internet and network activity information that we collect (such as IP address), information about your interactions with the app, and other related information about your usage of the app.
To send you information and marketing communications about our products and services such as tips, offers, and newsletters through emails and push notifications (only if you grant permission by enabling push notification on your mobile operating system settings).	The legal basis for the processing is your consent (art. 6(1)(a) of the GDPR). Where your consent is not required, for example, where we use your email for the purpose of sending you information about products and services related to or similar to the app, the legal basis is our legitimate interest (art. 6(1)(f) of the GDPR).	Identification and contact information you provide us (such as name, email address), identifiers and Internet and network activity information that we collect (such as IP address), and information we may receive from third-party advertising networks and platforms (such as unique identifiers).
If you choose to participate in one of our contests, sweepstakes, or promotions, to facilitate them, including to process and deliver entries and rewards and, in some cases, to incorporate your personal information in our marketing and advertising efforts, depending upon the terms of the contest, sweepstakes or promotion.	The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR).	Identification and contact information you provide us (such as name, email address, and social media handle), video content you may share with us (including your voice and image), and any other information you choose to share in connection with participation in any of our contests, sweepstakes, and promotions.
To install third-party tracking technologies to provide you with personalized ads. You can find more information on how these third parties process your personal data by reading their privacy policies listed in Section 12 (In-app Tracking Technologies).	The legal basis for the processing is your consent (Article 6(1)(a) of the GDPR). The collection of personal data by means third-party profiling tracking technologies is based on your consent (art. 122 of Italian Privacy Code). For more details, please see Section 12 (In-app Tracking Technologies).	Identifiers and Internet and network activity information (such as IP address, unique identifiers including IDFA or AAID, crash logs and diagnostic information, performance data such as app launch time, hang rate, or energy usage), information about your interactions with the app, and advertising data (such as advertisements seen), your ad tracking choices and consent to receive personalized ads (if granted), and inferences about your interests and preferences. IDFA (on iPhone or iPad) and AAID (on Android devices) are unique device identifiers provided by the operating system of your device, that allow advertisers to track and identify a user for advertising purposes. To disable this tracking see Section 4 (Your Choices with Regard to the Use of Your Personal Data).

3. Data Storage and Protection

Personal data may be processed by both automated and non-automated means and may be stored at our premises and on our service providers’ servers. We adopt technical and organizational measures designed to prevent the loss, improper use and alteration of your personal data. In some cases, we may also adopt data encryption and pseudonymization measures. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk.

Personal data processed for the purposes referred to in Section 2.a), 2.b), 2.f), 2.h), and 2.j) will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than three (3) years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.

Images, videos, and audio recordings processed for the purposes referred to in Section 2.c) will be kept for no more than three (3) years from the upload.

Personal data processed for the purposes referred to in Section 2.d) will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than one (1) year from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.

Personal data processed for the purposes referred to in Section 2.e), will be kept up to five (5) years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.

Personal data processed for the purposes referred to in 2.g) will be kept up to ten (10) years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.

Personal data processed for the purposes referred to in Section 2.i) will be kept up to two (2) years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.

Regarding personal data processed for the purposes referred to in Section 2.k), you can find more information about the retention period of your data by visiting the third parties’ privacy policies linked in Section 12 (In-app Tracking Technologies).

At the end of these specified periods, unless any legal obligations require a longer data retention, the processed personal data will be either deleted or anonymized. 

4. Your Choices with Regard to the Use of Your Personal Data

It is mandatory for you to provide your personal data for the purposes referred to in Sections 2.a), 2.e), 2.f) and 2.j). If you do not provide the personal data, you will not be able to enjoy the app’s services and features or participate in our contests, sweepstakes or other promotions that we offer.

Where we rely on your consent for the purposes referred to in Sections 2.c), 2.d) and 2.i), your provision of personal data is optional, and you have the right to withdraw your consent at any time. If you do not provide the personal data, you will still be able to enjoy the app’s services and features.

Where we rely on our legitimate interest for the purpose referred to in Sections 2.b), 2.d), 2.g), 2.h) and 2.i), you may, at any time, exercise your right to object to such processing as explained in Section 7 (Your Rights) below.

For the purposes referred to in Section 2.k), you can also manage how you share your IDFA (on iPhone or iPad) and AAID (on Android devices), which are unique device identifiers provided by the operating system of your device that allow advertisers to track and identify a user for advertising purposes. To disable this tracking:

• From iOS and iPadOS 14.5, go to Settings > Privacy > Tracking and tap to turn off or turn on Allow Apps to Request to Track or permission to track for a specific app. On previous iOS or iPadOS versions, go to Settings > Privacy > Advertising and turn on Limit Ad Tracking button.

• On Android devices, you can go to your device's Settings app or Google Settings app (differs depending on your device) > Services > Ads and turn on Opt out of Ads Personalization.

5. Recipients of Your Personal Data

We may share or disclose your personal data to the following categories of recipients:

• Vendors carrying out activities that are related or instrumental to our business and operational activities as outsourced data processors appointed in writing in accordance with Applicable Privacy Laws, or acting as autonomous data controllers (such as IT or storage service providers, mobile measurement partners, suppliers of mobile marketing services, and advertising networks and platforms).

• If we carry out a corporate transaction or operation (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions), your personal data may be disclosed to our advisers and any prospective purchaser's advisers, and may be one of the assets that is transferred to another owner.

• If you choose to participate in a contest, sweepstakes or promotion we offer, information and content you submit in connection with the contest or promotion may be shared publicly as part of our marketing and advertising efforts (for example, your video submission in a contest and your social handle could be shared in our social channels).

• Public, judicial or police authorities, within the limits established by applicable laws.

Personal data will not be disclosed for any reason other than those stated above, unless such disclosure is deemed necessary for the fulfillment of a legal obligation or if we request your consent.

Pursuant to Section 2.k), if you give your consent to install tracking technologies, you will allow third parties mentioned therein to collect personal data about you in order to show you customized and personalized advertising. If you want to learn more about their processing activities, please see the third parties’ Privacy Policies linked in Section 12 (In-app Tracking Technologies).

6. Transfers of Personal Data Outside the European Economic Area

We may transfer personal data from the European Economic Area (“EEA”), the UK or Switzerland to other countries outside the EEA. Such data transfers are based on appropriate safeguards in accordance with Applicable Privacy Laws, including (a) the standard contractual clauses developed by the European Commission; (b) the decisions of adequacy of the European Commission; or (c) binding corporate rules.

More information on the appropriate warranties is available for consultation at privacy@bendingspoons.com.

7. Your Rights

At any time and free of charge, you can exercise the following rights, as specified and subject to certain limitations and exceptions under Applicable Privacy Laws:

• Right of access. You have the right to obtain information about the processing of your personal data and to access it.

• Right to rectification. You have the right to ask for the updating, rectification or integration of your personal data.

• Right to erasure. You have the right to request the deletion of your personal data.

• Right to restriction of processing. You have the right to request the restriction of the processing of your personal data.

• Right to data portability. You have the right to obtain a portable electronic copy of your personal data.

• Right to object. Where we rely on our legitimate interest to process your personal data, you have the right to object to such processing, wholly or partly, on grounds related to your particular situation. In particular, you are entitled to object to the processing of your personal data for direct marketing purposes, including profiling.

• Right to withdraw your consent. Where we rely on your consent to process your personal data, you have the right to withdraw your consent, although the processing carried out before your withdrawal of consent will remain valid.

You also have the right to lodge a complaint before the competent national Data Protection Authority, in particular before the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.

To exercise your rights, you can submit a request following these steps:

1. Access the app from your device (if you do not have it on your device any longer, you can download it again and then access it without the need to purchase a subscription).

2. Long press four fingers on any screen within the app until a menu opens up.

3. Tap Send a Privacy Request and follow the instructions.

4. After you have sent your request through Send a Privacy Request, you may uninstall the app if you do not want to use it anymore.

If you have any other questions about privacy or data protection at Bending Spoons, you can contact us at privacy@bendingspoons.com. We may take reasonable steps to verify your identity prior to responding to your request.

8. Children’s Personal Data

The app is not intended for anyone under the age of 16. We do not knowingly collect personal data from children. If you believe we have received personal data from children under the age of 16, please email us at privacy@bendingspoons.com. If we learn that a user is under the age of 16, we will take reasonable steps to delete any processed data and close such user’s account.

9. Third-party Websites and Services

The app may include links to other websites or services operated by third parties. The activities described in this Privacy Policy do not apply to data processed by such third-party websites and services. We have no control over, and we are not responsible for, the actions and privacy policies of third parties and other websites and services.

10. Changes to this Privacy Policy

We may modify, integrate or update, in whole or in part, this Privacy Policy, and we will notify users of any modification, integration or update in accordance with Applicable Privacy Laws. If we make modifications, we will notify you by revising the date at the bottom of this Privacy Policy and, under certain circumstances, we may also notify you by additional means such as pop-up or push notifications within the app or our website, or email.

11. Additional Information for California Consumers

This section provides additional disclosures required by the California Consumer Privacy Act (“CCPA”).

a) Additional Information Related to Collection, Use, and Disclosure of Personal Information

We collect personal information from several sources: directly from you (for example, when you make purchases within the app or participate in a survey or contest); automatically when you use the app (for example, device information); and from other sources (for example, mobile measurement partners). We also generate inferences about you based on your use of the app and other information we collect.

In the preceding 12 months, we have collected the following categories of personal information: identifiers; internet or other electronic network activity information; characteristics of protected classifications under California or U.S. federal law (such as gender if you participate in a survey); commercial information (such as purchases you make in the app); approximate geolocation information (such as country); audio and visual information (such as videos you share with us if you participate in a contest); inferences; and other information that relates to or is reasonably capable of being associated with you. For details about the personal information we collect, please see Section 2 (Categories of Personal Data that We Collect, Purposes and Legal Bases for Our Processing) above. We collect personal information for the business and commercial purposes listed in the chart in Section 2 above.

We may share your personal information with the categories of third parties as described in Section 5 above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes: identifiers, internet and electronic network activity information, characteristics of protected classifications under California or U.S. federal law; commercial information; approximate geolocation information; and other information that we have inferred about you or that relates to or is reasonably capable of being associated with you.

We do not sell your personal information. We do allow our advertising partners to collect certain device identifiers and electronic network activity via our app to show ads that are based on your interests. If you prefer to limit this activity, your device may include a feature (such as “Limit Ad Tracking” on iOS, or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for interest-based advertising purposes.

b) Rights of California Consumers

Subject to certain limitations, the CCPA provides California consumers the right to:

• Request more details about the categories and specific pieces of personal information that we process.

• Request the deletion of their personal information.

• Opt out of “sales” of personal information that may be occurring.

• Not to be discriminated against for exercising these rights.

If you’re a California consumer, to exercise these rights, you can submit a request following the steps below:

1. Access the app from your device (if you do not have it on your device any longer, you can download it again and then access it without the need to purchase a subscription).

2. Long press four fingers on any screen within the app until a menu opens up.

3. Tap Send a Privacy Request and follow the instructions.

4. After you have sent your request through Send a Privacy Request, you may uninstall the app if you don’t want to use it anymore.

If you have any other questions about privacy or data protection at Bending Spoons, you can contact us at privacy@bendingspoons.com. We may take steps to verify your request by asking you to provide information that matches information we have on file about you. California consumers can also designate an authorized agent to exercise these rights on their behalf, but we will require proof that the person is authorized to act on their behalf and may also still ask them to verify their identity with us directly.

12. In-app Tracking Technologies

When we refer to “tracking technology/technologies” in this Policy, we mean any technology that stores or accesses information on the user’s device, including SDKs, tracking pixel, HTML5 local storage, local shared object, and fingerprinting technique.

Tracking technologies are usually classified by purpose (Technical, Analytics, Profiling) and by publisher (First-party, Third-party).

This classification is important because different legal requirements apply based on how the tracking technologies are classified.

Below you will find the types of tracking technologies as classified with some practical examples.

By purpose

Technical tracking technologies

Technical tracking technologies are used for the purpose of transmitting messages over an electronic communication network or to provide a service specifically requested by the user.

Thus, technical tracking technologies are essential for the correct functioning of the app and to provide the service offered to and requested by the user.

For example, technical tracking technologies can be used to monitor sessions, store specific server access information related to the user configuration, facilitate the use of online content, or keep track of items in a shopping cart or information used to fill in a form.

Technical tracking technologies do not need your consent.

Analytics tracking technologies

Analytics tracking technologies may be used to assess the effectiveness of an information society service provided by a publisher, evaluate and improve the design of an app, or help measure its traffic.

In other words, analytics tracking technologies may be used to track the traffic and performance of an app, by collecting aggregate data on the number of users and how they interact with the app to improve its services.

For example, analytics tracking technologies may collect information about how users access an app, including the number of users, possibly grouped by geographical area, time slot, how long users stay on the app, what parts of the app they interact with, or the number of users who used a particular feature.

Analytics tracking technologies need your explicit consent. However, analytics tracking technologies are equated to technical trackers and, thus, do not need your consent if:

• they are only used to produce aggregated statistics that are performed by way of the controller’s own resources and do not turn into activities that go beyond statistical counting and enable business-related decision-making; or

• the third parties do not match the analytics trackers' data with any other information and do not forward such data to other third parties.

Profiling tracking technologies

Profiling tracking technologies may be used to evaluate certain personal aspects relating to users and trace specific actions or recurring behavioral patterns in the use of the offered functionalities back to specific, identified or identifiable individuals for the purpose of grouping them within homogeneous, multi-sized clusters. This is aimed to enable the company to analyze and predict personal aspects concerning the users, provide them with increasingly customized services beyond what is strictly necessary for the delivery of the service, and also send targeted advertising messages in line with the preferences expressed by the user during their in-app activities.

In other words, profiling tracking technologies may be used to convey behavioral advertising, measure the effectiveness of ads, or to customize the services offered in line with the user’s monitored behavior.

For example, profiling tracking technologies can be used to create user profiles and offer content in line with the user’s interests, send targeted ads or messages, conduct statistical analysis or other research activities to improve our products and services and measure the effectiveness of our campaigns.

Profiling tracking technologies need your explicit consent.

By publisher

First-party tracking technologies

First-party tracking technologies are installed and managed directly by the owner of the app which will process the collected data for its own purposes.

Third-party tracking technologies

Third-party tracking technologies are installed and managed by different apps or developers either for our purposes or for the third party’s own purposes.

The data collected by these third parties is governed by their own specific privacy policies and terms and conditions over which we have no control. Thus, for further information about this data processing activities, please refer to the privacy policy of such third parties as indicated in the following section ("Types of tracking technologies used by the app”).

Third-party non-anonymized analytics and/or profiling trackers need your consent. You can manage this consent at any time by accessing the “Privacy Settings” within the app.

Types of tracking technologies used in the app

This app installs the following types of tracking technologies:

Name	Purpose	Retention period	Publisher (i.e., first-party or third-party)	Description	Third-party Privacy Policy (where applicable)
Splice SDK (technical)	Technical	3 years. See Section 3 (Data storage and protection) for more details.	First-party	Our internal software development kit (SDK). It is essential for the app to function correctly.	N/A
Firebase Crashlytics	Technical	3 years. See Section 3 (Data storage and protection) for more details.	Third-party	Firebase is a tool provided by Google which is essential for the app to correctly interact with the backend and provide the user with the key features.	https://policies.google.com/privacy
Firebase Dynamic Links	Technical	3 years. See Section 3 (Data storage and protection) for more details.	Third-party	Firebase is a tool provided by Google which is essential for the app to correctly interact with the backend and provide the user with the key features.	https://policies.google.com/privacy
FirebaseAuth	Technical	3 years. See Section 3 (Data storage and protection) for more details.	Third-party	Firebase is a tool provided by Google which is essential for the app to correctly interact with the backend and provide the user with the key features.	https://policies.google.com/privacy
Google Sign In	Technical	Defined by the Third Party	Third-party	Thanks to this SDK developed by Google we can provide you with a secure, fast, and easy way to log in into our app using Google.	https://policies.google.com/privacy
Snap Kit SDK	Technical	Defined by the Third Party	Third-party	Thanks to this SDK developed by Snapchat we can provide you with a secure, fast, and easy way to interact with your Snapchat account.	https://values.snap.com/en-GB/privacy/privacy-policy
Tik Tok SDK	Technical	Defined by the Third Party	Third-party	Thanks to this SDK developed by TikTok we can provide you with a secure, fast, and easy way to interact with your TikTok account.	https://www.tiktok.com/legal/page/eea/privacy-policy/en
Splice SDK (statistical analytics)	Analytics	3 years	First-party	Our internal software development kit (SDK). It allows us to produce aggregated statistics.	N/A
Firebase	Analytics	3 years	Third-party	Firebase is a tool provided by Google which is essential for the app to work properly. When analytics features are enabled, it can help us to improve app’s traffic and performance.	https://policies.google.com/privacy
Splice SDK (profiling)	Profiling	3 years	First-party	Our internal profiling software development kit (SDK). It allows us to provide customized services.	N/A
Firebase	Profiling	3 years	Third-party	Firebase is a tool provided by Google which is essential for the app to work properly. When profiling features are enabled, it can help us to measure the effectiveness of our ads.	https://policies.google.com/privacy
Adjust	Profiling	3 years	Third-party	Adjust is a mobile attribution tool. It helps us to measure the effectiveness of our ads.	https://www.adjust.com/terms/privacy-policy/
[Only for Android users] AppLovin	Technical Profiling	Defined by the Third Party	Third-party	AppLovin allows us to show you advertising. When profiling features are enabled, advertising is customized according to your preferences. When profiling features are disabled, it still performs technical activities.	https://www.applovin.com/privacy/

Tracking technologies settings

You can activate or disable (in whole or in part) profiling and third-party analytics tracking technologies at any time through the “Privacy Settings” within the app. As for Meta Audience Network SDK, you can manage your choices directly on Meta's website.

In case of withdrawal of consent, your data will no longer be collected through those trackers but we will continue processing the data collected before the withdrawal.

You cannot deactivate first-party analytics tracking technologies since they are equated to technical trackers and, thus, are not based on your consent. However, you can opt out of the further processing of your data collected by means of such trackers by sending an email to privacy@bendingspoons.com.

With regards to your rights under applicable Data Protection Laws, please refer to Section 7 (Your Rights) above.

Last updated: December 29, 2023