Welcome to our website Ferrari Store (“ the Website”).
In compliance with applicable privacy laws, including EU Regulation no. 2016/679 (“GDPR”), the California Consumer Privacy Act (“CCPA”) and regulations applicable in your jurisdiction (“National Data Protection Laws”), which, with respect to China, shall include the PRC, Personal Information Protection Law and other applicable PRC laws and regulations, this Privacy Notice explains how Ferrari S.p.A and YOOX NET-A-PORTER GROUP S.p.A. (“we”, “us”, “our”) collect your personal information as you use the Website, how we use this personal information, with whom we share your personal information, and your choices in connection with this.
(1) CONTROLLER AND DATA PROTECTION OFFICER
- YOOX NET-A-PORTER GROUP S.p.A. (“YOOX NET-A-PORTER GROUP”), company with sole shareholder subject to direction and coordination of Compagnie Financière Richemont S.A., with registered office at via Morimondo, 17 – Milan 20143, Italy, as independent Data Controller.
The personal data that YOOX NET-A-PORTER GROUP processes is the data that you provide when you place an order and purchase items, as well as the data we collect as you navigate or you use the services offered on the Website.
For any clarification, request, or requirement connected to your privacy and the processing of your personal data, please contact us at any time by selecting ‘privacy’ and sending a request to our Customer Care or by writing to the registered office of YOOX NET-A-PORTER GROUP S.p.A.. If you so wish, you may also contact our Data Protection Officer (“DPO”), by writing to the aforementioned address, or by sending an email to DPO@ynap.com.
- Ferrari S.p.A. (“Ferrari”), with registered office at via Emilia Est, 1163 - Modena 41122, Italy, as independent Data Controller. Ferrari processes your personal data in order to create your account on the Website, for marketing and profiling activities upon your express consent, and to support you through the Live Chat service. For any clarification, request, or requirement linked to your privacy and the processing of your personal data, please contact us by writing to Ferrari S.p.A., via Abetone Inferiore 4, 41053 Maranello (MO), Italy. If you so wish, you may also contact our Data Protection Officer (DPO) by writing to the aforementioned address, or through the interactive webform.
(2) COLLECTION OF YOUR PERSONAL INFORMATION
We collect personal information, which is information that identifies, relates to, describes, can be associated with, or could reasonably be linked, directly or indirectly, to you.
- Information you provide to us
If you choose to engage in the services offered on the Website, we will collect personal information from you. We collect personal information from you when you:
- Create a Ferrari account. You have the option to create a Ferrari account on the Website for faster purchases, to monitor your orders and returns, and to save your favorite items. To do so, we will collect your personal identifiers (name, email address, date of birth and telephone number) and protected classifications (gender). We use this personal information to create and maintain your account with us and to communicate with you about your account, purchases, and the Website. The legal basis for this is performance of our contract with you (Art. 6, par. 1, let. b of the GDPR), unless the applicable National Data Protection Laws in your jurisdiction state otherwise. Once your account is created, we will store your username and password.
- Contact us. When you send us a question or inquiry, or ask for other support, you will need to provide us with personal identifiers (name and email address), protected classifications (gender), and any other information you choose to provide in your correspondence. We use this personal information to reply to your questions or inquiries, troubleshoot where necessary, and address any issues you experience with the Website or the services offered thereon. The legal basis for this is performance of our contract with you (Article 6, par. 1, let. b of the GDPR), unless the applicable National Data Protection Laws in your jurisdiction state otherwise.
- Make a purchase. To facilitate your shopping experience and to manage the services offered by Ferrari Store, YOOX NET-A-PORTER GROUP will collect personal identifiers (name, email address, shipping address and telephone number) and customer records information (cardholder’s name, payment card number, expiration date, CVV or PayPal account and billing address). YOOX NET-A-PORTER GROUP uses this personal information to manage the services offered by the website, to fulfill orders placed, and complete all activities related thereto, including operations pertaining to administrative and fiscal requirements, to reply to requests via the contact form, and manage any product returns. The legal basis for this is performance of our contract with you (Article 6, par. 1, let. b of the GDPR), unless the applicable National Data Protection Laws in your jurisdiction state otherwise.
- Profiling activities. If you opt in, Ferrari may use the personal data described in this section to analyze your behavior, habits and propensity to consume to enhance products and services provided by Ferrari, to meet your expectations and to send you marketing communications we feel may be of interest to you, if you also have opted in to receive direct and indirect marketing communications. In doing so, Ferrari will analyze your preferences and interests using automated analysis techniques that provide Ferrari with inferences derived from your data, and including profiling. The legal basis for this is your consent (Article 6, par. 1, let. a of the GDPR), unless the applicable National Data Protection Laws in your jurisdiction state otherwise. You may revoke your consent at any time by clicking the ‘unsubscribe’ link provided within each email. This link will redirect you to our consent management page where you can opt out of our newsletters and marketing communications.
- Subscribe to direct and indirect marketing communications. If you opt in, Ferrari may also use your personal data (e.g. email address) to send you marketing communications as well as advertising on Ferrari products, services, events, new collections or performing market research (direct marketing) as well as on Ferrari’s commercial partners’ products belonging to different product categories (e.g. companies operating in the oil, automotive, IT sectors, etc.) (indirect marketing). This data may be processed by automated or electronic means including via email, websites and cell apps. In doing so, Ferrari will analyze your preferences and interests using automated analysis techniques that provide Ferrari with inferences derived from your data, and including profiling. The legal basis for this is your consent (Article 6, par. 1, let. a of the GDPR), unless the applicable National Data Protection Laws in your jurisdiction state otherwise. You may revoke your consent at any time by clicking the ‘unsubscribe’ link provided within each email. This link will redirect you to our consent and newsletters management page where you can opt out of our marketing communications.
- Web Push Notifications. Upon your explicit consent, Ferrari will collect certain categories of your personal data, such as the language you use when browsing the Website and the version of the Website you use (country/region), information about the device and browser you use, the time and date you consented to receive web push notifications, the date of your last visit to the Website. Ferrari will use this information to send you notifications about products and other commercial news regarding the Ferrari Store. In order to send you these notifications, we use a technology similar to cookies (in particular, “HTML5 Local Storage”), which stores the information in the local memory of your browser/device. The legal basis for this is your consent Art. 6, par. 1, let. a of the GDPR), unless the applicable National Data Protection Laws in your jurisdiction state otherwise.
We may also use the personal information we collect as described in this section to improve our products and services, to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION. This is part of our legitimate interest in the performance of our contractual obligations, protection of legal rights, and compliance with legal obligations. We may also deidentify or aggregate the personal information for benchmarking purposes.
Your personal information may be processed for each of the above purposes using automated or electronic methods and, in particular, by email or any other IT channel (e.g. automated calls, SMS, MMS), fax, or any other IT channel (e.g. websites, cell app).
Sharing your personal information is optional. However, if you opt not to share data that has been marked as mandatory, it will be impossible for us to provide our services. Should you not share the optional data, however, the services will be provided in any case.
- Information collected automatically.
Cookies and tracking technologies
In addition to the personal information you provide directly, we may also collect information from you automatically as you use the Website. This information includes the following internet or other electronic network activity and location information:
- Usage information. This includes information regarding your interaction with the Website, such as which pages you visit, the frequency of access, how much time you spend on each page, what you click on while on the Website, and referring Website addresses.
- Device information. This includes certain information about the device that you use to access the Website, such as browser type, browser language, hardware model, operating system, and your preferences.
- Location information. This includes information about your location, which may be determined through your IP address.
We collect this information as part of our legitimate interest to improve the functionality and efficiency of the Website and in order to provide the Website to you.
- Technical. We use essential cookies to authenticate users, prevent fraudulent use of the Website, and to allow the Website and its features to function properly.
- Functional. We use functional cookies to provide enhanced functionality and personalization, to remember your login information, to remember your preferences, to diagnose server and software errors, and, in cases of abuse, to track and mitigate the abuse.
- Analytics. Analytics cookies allow us to recognize and count the number of users to the Website, see how users interact with the Website and its different functions, and when users are using the Website. We use this information to improve the Website.
- Profiling. Performance cookies collect information about how you use the Website and help Ferrari, for example, to identify especially popular areas of the Website. In this way, we can adapt the content of our Website more specifically to your needs and thereby improve what we offer you.
Particular third-party cookies on the Website that should be noted include:
- Bing Ads. Bing Ads is a remarketing service provided by Microsoft. Ferrari uses Bing Ads to serve you advertisements based on your past visits to the Website. You can learn more about the privacy practices of Microsoft here. Such sharing may be deemed a sale under the CCPA. To opt out of this sharing of Bing Ads, you can follow the instructions found here.
- Criteo. Ferrari, through its own providers, places tags on its properties for Criteo to collect browsing information and create customized ads to serve to users. Criteo creates the ads, decides which ad to serve and where. Such sharing may be deemed a sale under the CCPA. You can learn more about the privacy practices of Criteo and opt out of this sharing here.
- Hotjar. We use Hotjar in order to better understand user experience and to optimize the Website. Hotjar allows us to better understand users’ experience and this enables us to build and maintain the Website. For further details, please see the ‘about Hotjar’ section of Hotjar’s support services. You can opt-out of Hotjar here.
- Information collected through other sources.
Social media listening (“SML”). From time to time, Ferrari may use SML tools to extract information (e.g. users’ comments concerning Ferrari, username, etc.) from web sources (e.g. blogs, forums, etc.) and social media channels. This activity is based on Ferrari’s legitimate interest to find insights into Ferrari brand's visibility on social media channels as well as to assess the impact of our web campaigns (Article 6, par. 1, let. f of the GDPR), unless the applicable National Data Protection Laws in your jurisdiction state otherwise. For this purpose, Ferrari may process only publicly available information and derive statistical analysis from it.
Social networks. If you interact with Ferrari through social network platforms including Facebook, LinkedIn, YouTube and any other similar platforms (“Social Networks”) when you complete specific forms (e.g. request of information, etc.) and/or when you interact with Ferrari’s official Social Network pages/profiles, Social Networks may provide us with your personal data (e.g. email, name, surname, country of origin, address, street number, town, postcode, city, telephone number), data relating to your vehicle (e.g. current model brand, next vehicle purchase), your interactions on Social Networks (e.g. posts that you like, private messages you may send to Ferrari, etc.). According to the settings you have chosen on your Social Networks profile, Ferrari may be able to receive additional data such as your age, groups you have joined, etc., which in certain cases may lead Ferrari to identify you. Ferrari may process your data to reply to your posts, requests and queries, to perform statistical analyses and market research on the users who interact with Ferrari pages and/or Ferrari websites as well as, if you opt in, for marketing activities as described in section (A).
Furthermore, in the event that you choose to register on Ferrari websites through your Social Network account, we will receive some personal data (e.g. email, password, name, surname, date of birth, gender, job role, country, citizenship, address, telephone) from the Social Networks of your choice. The legal basis for this processing is the execution of our contract with you (Article 6, par. 1, let. b of the GDPR), unless the applicable National Data Protection Laws in your jurisdiction state otherwise.
Please note that this section (C) only refers to Ferrari’s data processing. Ferrari is not liable in the event of any unauthorized disclosure of your information by third-party social media channels in breach of the options you have selected thereto and/or any consents you have provided. You may refer to such third-party social media channels websites and Social Networks to know more about their privacy policies relating to the data and consents you may have provided to them.
Please note that certain Social Networks may not be available in China, therefore such activity may not be applicable to you if you reside in China.
Ferrari partners. In the event that you take part in initiatives or events organized by Ferrari’s commercial partners and/or request the latter to provide a service to you, Ferrari may receive your personal data in order to follow up on the requested service and/or the activities included in the scope of the initiative or event (e.g. Ferrari could reward the winners of a competition organized by our commercial partners, etc.). The legal basis for this processing is the execution of our contract with you (Article 6, par. 1, let. b of the GDPR), unless the applicable National Data Protection Laws in your jurisdiction state otherwise.
(3) HOW WE SHARE YOUR PERSONAL INFORMATION
Ferrari may need to make the personal information identified in this Privacy Notice available within Ferrari, with service providers, or with other third parties. These instances include:
Within Ferrari. Ferrari may share your personal information with Ferrari subsidiaries for legitimate business purposes and general business management. The legal basis for this is Ferrari’s legitimate interest in carrying out our business efficiently.
With Service Providers. Ferrari may share your personal information with our service providers that assist us in providing the Website. The legal basis is our legitimate interest in providing the Website efficiently. These service providers include communication providers, web-hosting providers, IT support, our customer management platform, shipping providers, payment processors, call center providers, marketing providers, and e-commerce providers. This also includes sharing of personal information with our service provider YOOX NET-A-PORTER GROUP that manages the Website on Ferrari's behalf. We may also share your personal data with Social Networks for marketing purposes.
With Third Parties. We may need to disclose your personal information to third parties, such as legal advisors, law enforcement agencies, or governmental/regulatory bodies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, prevent harm, for risk management purposes, and to comply with our legal obligations. The legal basis for this is compliance with the law, compliance with legal obligations, and our legitimate interest in the protection of the rights of others.
In the Event of a Corporate Reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, Ferrari would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. Ferrari would also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings. The legal basis for this is our legitimate interest in carrying out business operations.
With Your Consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the Personal Information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time.
(4) YOUR PERSONAL INFORMATION CHOICES AND THE POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE YOUR DATA
Correct or view your information. You may access your Ferrari account to correct or view certain personal information you have provided to us and that is associated with your account.
Online advertising. To opt out of interest-based advertising generally or to learn more about the use of this information by our service providers, please visit the Network Advertising Initiative or the Digital Advertising Alliance.
Marketing emails. You may opt out of receiving marketing emails from Ferrari by clicking the ‘unsubscribe’ link provided withing each email. Please note that we will continue to send you notifications necessary to the Website, your account, or requested products or services.
Providing your personal data is optional. However, if you do not provide personal data that has been marked as mandatory, it will not be possible for us to provide our services.
Should you not provide the remaining and optional personal data, our services will nevertheless be able to be provided.
Please note that if you do not provide your personal data when requested, this may prevent you from benefiting from our Live Chat service.
Providing Data for the purposes of marketing and profiling activities is always optional.
(5) RIGHTS OF INDIVIDUALS UNDER THE GDPR
If our processing of your personal information is subject to the GDPR, you have the following rights concerning your personal information that has been processed:
- Right to access. You have the right to ask us for copies of your personal data. This right entails some exceptions, which means you may not always receive all personal data we process.
- Right to rectification. You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Right to erasure. Under certain circumstances, you have the right to ask us to erase your personal data.
- Right to restrict processing. Under certain circumstances, you have the right to ask us to restrict the processing of your personal data. Please see YOUR PERSONAL INFORMATION CHOICES AND THE POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE YOUR DATA for additional ways in which you can restrict the processing of your personal data.
- Right to object to processing. You have the right to object, at any time, for reasons arising from your particular situation, to the processing of your personal data, which is carried out on the basis of our legitimate interests. See YOUR PERSONAL INFORMATION CHOICES AND THE POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE YOUR DATA for additional ways in which you can object to the processing of your personal data.
- Right to data portability. You have the right to ask that we transfer the personal data you gave us from one organization to another, or give it to you, in a structured, ordinarily used, and readable format.
- Right to lodge a complaint. You have the right to lodge a complaint with a supervisory authority.
To exercise these rights, please contact Ferrari through the interactive webform or by writing to Ferrari S.p.A, via Abetone Inf. 4; I-41053, Maranello, (MO), Italy. You may also contact YOOX NET-A-PORTER GROUP’s Customer Care.
a. Personal data transfer outside of the European Economic Area
Within our contractual relations, we may transfer personal data to countries outside of the European Economic Area (“EEA”). In the event that personal data is transferred outside of the EEA, we will use appropriate contractual measures to guarantee an adequate protection of personal data, including implementation of agreements based on the standard contractual clauses adopted by the EU Commission.
(6) CALIFORNIA RESIDENTS
This section supplements the other portions of this policy and applies solely to the personal information collected online about California consumers. This section is intended to address the relevant notice requirements of the CCPA, and uses certain terms that have the meaning given to them in the CCPA.
To the extent the CCPA applies to the processing of your personal information you would be entitled to the rights listed below.
• Right to Access. You have the right to request we provide you the categories or specific pieces of personal information we collected; the purpose why we collected, shared, or sold that information; the categories of sources from which we collected your personal information; the categories of third parties to whom we disclosed your personal information; the categories of personal information we sold or shared; the categories of third parties to whom we sold or shared your information; and the categories of personal information we disclosed for a business purpose.
• Correction. You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
• Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions.
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, correct, delete, or opt-out under the CCPA.
To exercise your rights, described above, you can:
For Ferrari you may submit a verifiable consumer request (i) by email at email@example.com; (ii) by telephone at 1-877-933-7727 or (iii) through the CCPA interactive webform.
For YOOX NET A PORTER GROUP:
• call the toll-free number 1-833-873-2288 from Monday to Friday from 9 a.m. to 11 p.m., excluding public holidays; or
• write to Customer Care by selecting the "privacy" topic in the relevant webform in the "Contact us" section of the Website; or
• contact us directly at the address indicated above. If you exercise your rights, we may require you to provide certain information to verify your identity (such as your name, email address, phone number and/or address).
You may make a verifiable consumer request for access twice within a twelve (12) month period.
Except for requests to opt out, you must provide us with sufficient information (i.e. name, surname and e-mail address) that allows us to reasonably verify you are the person about whom we collected the personal data and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity with the information provided, we may ask you for additional pieces of information. The interactive webform contains the information that Ferrari needs to verify your identity and review your request.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal data. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.
If you are a consumer in the State of Nevada, you may request to opt out of the current or future sale of certain of your personal data. We do not currently sell any of your personal data under Nevada law, nor do we plan to do so in the future. If you have any questions regarding our data privacy practices, or would like to opt out of the future sale of your personal data, please contact Ferrari at firstname.lastname@example.org and/or YOOX NET A PORTER GROUP’s Customer Care
(8)RIGHTS OF INDIVIDUALS UNDER THE APPLICABLE NATIONAL DATA PROTECTION LAWS IN CHINA
To the extent of which the National Data Protection Laws in China apply to the processing of your personal data, you are entitled to the rights listed below.
- Right to access. You have the right to ask Ferrari for copies of your personal data. To the extent permissible by applicable National Data Protection Laws in China, some exceptions apply to this right, which means you may not always receive all personal data we process.
- Right to rectification. You have the right to ask Ferrari to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
You may request us to delete your personal information if:
（1）we process your personal data in violation of applicable laws and regulations;
（2）we collect and use your personal data without obtaining your consent;
（3）we process your personal data in a way that seriously violates our agreement with you;
（4）you no longer use our products or services;
（5）we terminate our services and operations, or the retention period has expired.
For avoidance of doubt, we may reject your request for erasure if: (A) we have other legal grounds for continuing to process your personal data; (B) the legal retention period has not yet expired; or (C) it is technically impossible or difficult to achieve the deletion of the applicable personal data (in which case, we will cease processing activities other than storing and taking necessary safeguard measures in respect of the applicable data).
- Right to restrict or to Object to processing. You have the right to ask Ferrari to restrict, or you can object to, the processing of your personal data as provided for under the applicable National Data Protection Laws in China.
- Right to data portability. You have the right to ask that we transfer the personal data from us to another organization subject to the conditions set forth by the applicable PRC data protection authority.
- Right to lodge a complaint. You have the right to lodge a complaint with a supervisory authority in China.
- Any other right that you may have under the applicable National Data Protection Laws in China.
You may ask Ferrari and/or YOOX NET- A-PORTER GROUP for further information or clarification with respect to personal data processing activities, this Privacy Notice or your rights as the data subject by contacting us as per the following means:
- Ferrari S.p.A., with registered office in via Emilia Est, n. 1163, Modena, Italy, headquartered in via Abetone Inferiore, n. 4, Maranello, Italy. Data Protection Officer: email@example.com.
- YOOX NET-A-PORTER GROUP S.p.A., company with sole shareholder subject to direction and coordination of Compagnie Financière Richemont S.A., with registered office at via Morimondo, 17 – Milan 20143, Italy. You may contact us at any time by selecting ‘privacy’ and sending a request to our Customer Care, or by writing to the address of the registered office of YOOX NET-A-PORTER GROUP S.p.A.. If you so wish, you may also contact our Data Protection Officer (“DPO”), by writing to the aforementioned address, or by sending an email to DPO@ynap.com.
We will normally respond to your request or question within thirty (30) days after verifying your identity unless the applicable National Data Protection Laws in China state otherwise.
a. Personal data transfer outside of your jurisdiction.
In order to centralize the storage and processing of personal data within Ferrari Group and for efficiency and security, we will store your personal data at data centers within the EEA, and we will ensure that your personal data is protected in accordance with the requirements and standards under the GDPR, and, in any event, at such level no lower than the requirements under the applicable National Data Protection Laws in your jurisdiction.
We keep your personal information for a limited period of time depending on the purpose for which it was collected. After such period, your personal information will be deleted or otherwise rendered anonymous in an irreversible way. The retention period is different depending on the purpose of the processing. For example, the personal information collected when items are purchased on the Website is processed until all administrative and accounting formalities have been completed. Therefore, it is kept on file in conformity with the local tax legislation, while the personal information used to send you our newsletter is kept until you request that we stop sending it. Ferrari retains the personal information for ten years from the time it was provided for marketing and profiling purposes unless consent is revoked. If consent is revoked, your personal information may not be processed for the aforementioned purposes, but may still be kept to manage any objections and/or disputes. The data used to manage Web Push Notifications will be retained up to the point in which consent is revoked by the data subject or up to 365 days from the last visit made to the Website by the data subject. Hashed data used for Custom and Lookalike Audiences is deleted once Social Networks have completed the matching process.
You can revoke your consent to receive these personalized commercial notifications (depending on your browser) at any moment. As part of the Live Chat service, text messages sent by the user, including attachments, will be stored for 6 months on the server of the external service provider we use, while the images taken during a video call are not stored. The Data processed for the purposes of registering to Live Chat will be kept for the time necessary to provide the service, except in the case in which the cancellation of the registration is requested.
(10) DO NOT TRACK
We do not respond to Do Not Track (“DNT”) requests. Do Not Track is a preference you can set in your web browser to inform the Website that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. For further details, please click here
The processing of your personal data takes place using IT and manual tools, with logic strictly related to the purposes of the processing indicated above and, in any case, in order to guarantee the protection, confidentiality and security of the data. We implement and maintain reasonable security measures to protect the personal information we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you.
The Website and the services offered thereon are not intended for individuals under the age of eighteen (18) years.
(13) LINK TO THIRD-PARTY WEBSITES
Third-party websites accessible from this Website are under the third party responsibility.
We decline all responsibility concerning requests and/or provision of personal data to third-party websites.
(14) AMENDMENT OF THIS PRIVACY NOTICE
This Privacy Notice is subject to change. Changes to the Privacy Notice will be posted on this page and will indicate the date on which changes go into effect. Please check back frequently and review the Privacy Notice for any changes. If we make any changes that materially affect your privacy rights, we will notify you via email or by prominent posting on the Website.