Website data protection statement and at the same time information for data subjects pursuant to Article 13 and Article 14 of the EU General Data Protection Regulation

Privacy Statement

Website data protection statement and information for data subjects (Art. 13,14  EU General Data Protection Regulation)

We recognize the importance of protecting your personal information and are committed to processing it responsibly and in compliance with applicable data protection laws in all countries in which our group operates. This Privacy Statement describes Kontron's general privacy practices that apply to personal information we collect, use and share about consumers and other individuals within our clients, business partners, suppliers and other organizations with which Kontron has or contemplates a business relationship.

General Information about the controller

Kontron Europe GmbH
Gutenbergstraße 2
85737 Ismaning
Germany

Managing Directors: Michael Riegert, Helmut Fischer

If you have a question related to this Privacy Statement, please contact us by using 

datenschutz@kontron.com

Your message will be forwarded to the appropriate member of Kontron's Data Privacy Team, such as local data protection officers.

Kontron is not the controller in situations such as (i) personal data is processed in connection with a contractual relationship, or with entering into a contractual relationship with a specific Kontron subsidiary. In this case the controller of personal data is the Kontron contracting company, which is the legal entity with which you or your employer have, or will have, the contract; and (ii) personal data collected on the physical site or location of a Kontron subsidiary. In such a case that specific subsidiary is the controller of the personal data.

Where a Kontron subsidiary controls (not established in the European Economic Area) is required to appoint a legal representative in the EEA, the representative for all such cases is Kontron.

GENERAL INFORMATION ON THE DATA PROCESSING

Basis for the Processing

We may process personal data relating to you if one of the following applies:

• you have given your consent for one or more specific purposes.
• the provision of personal data is necessary for the performance of an agreement with you, your company or a third party, and/or for any pre-contractual obligations or any requests thereof;
• processing is necessary for compliance with a legal obligation to which we are subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority;
• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

In any case, we will gladly help you to clarify the specific legal basis that applies to a specific processing.

Purpose for the processing of personal data

We may collect your personal information as an individual for various purposes, such as the following:

• Responding to your request for information, order, or support services

When you contact us - online or offline - in connection with a request for information and/or marketing material, to order a product or service, to provide you with support, we collect information necessary to fulfill your request and provide you with our services as requested by you.  For instance, we collect your name and contact information, details about your request and your agreement with us and if applicable, the delivery and invoicing of your order and we may include client satisfaction survey information. We retain such information for administrative purposes and in connection with our relationship with you. For ordering of most services and products we require you to have registered at Kontron Customer Section, Kontron Partner Portal, or Kontron Webshop, in which case you need to provide us with your name, email address, address, country location and other information related to your order.

If you request something from Kontron, for example, a product or service, a callback, or specific marketing materials, we will use the personal data you provide to fulfill your request. To help us do this, we may share information with Kontron's business partners if needed, as e.g. financial institutions, shipping companies, postal or government authorities, such as customs authorities, involved in fulfillment. We will retain your information for potential future interactions with you and will use the information solely for identifying you as one of our business partner and for staying in touch with you. We may use your personal information to support products or services you have obtained from us, such as notifying you of a product update or fix. We may combine your information with information from other interactions with you to provide you with more valuable suggestions in relation to product support. We may also contact you as part of our customer satisfaction surveys or for market research purposes.  

In the course of providing technical support to you, we may sometimes have incidental access to data that you have provided to us or data that is located on the products. This data may contain information about you, your organization's employees, customers, partners, or suppliers. This Privacy Statement does not apply to our access to or handling of this personal information; the conditions regarding the handling and processing of this data is covered by a specific data processing agreement, which must be concluded between you and Kontron in such a case. If you notice, that such an agreement is needed between your company and us, please don’t hesitate to contact us.

This also applies to our webshop.

• Contacting employees of our customers, partners and suppliers
  In our relationship with clients, partners and suppliers, they also provide us with business contact information (such as name, business contact details, position or title of their employees, contractors, advisors and authorized users) for purposes such as contract management, fulfillment, delivery of products and services, provision of support, invoicing and management of the services or the relationship. When you provide us with your business contact information (such as by handing over a business card) we may use this to communicate with you.
   
• Marketing
  Most information we collect about you comes from our direct interactions with you. When you register for an event we may collect information (online or offline) in relation to the event organization, and during an event, such as participation in sessions. We combine the personal information we collect to develop aggregate analysis and business intelligence for conducting our business and for marketing purposes. You can choose to receive information by email, telephone or postal mail about our products and services, or sign-up for subscriptions. When visiting our websites or using our services we may provide you with personalized information. The personal information you provide to Kontron, as well as the personal information we have collected about you indirectly, may be used by Kontron for marketing purposes, i.e, to keep you informed about events, products, services and solutions that Kontron sells and which may complement an existing product portfolio. Before we do so, however, we will offer you the opportunity to choose whether or not to have your personal information used in this way. You may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each e-mail you may receive, by indicating so when we call you, or by contacting us directly.

When registering for our newsletter, you provide us with your email address and, on an optional basis, other information. We use these data solely for the purpose of sending you the newsletter. We retain the data that you disclose in your newsletter application until you cancel your subscription to our newsletter. You can unsubscribe at any time via the link in the newsletter intended for this purpose, or by sending us the appropriate notification. By unsubscribing, you revoke the use of your email address. We also use your email address, which we receive in connection with the sale of a product or service, exclusively for direct advertising in the form of our newsletter for products or services that we sell that are similar to the ones you ordered, provided that you have not objected to having your email used in this way. You may object to the use of your email address at any time without incurring any costs other than the transmission costs according to the basic rates. Your objection (and thus the cancellation of our newsletter) can be communicated by sending the appropriate message to our email address (see the Legal Notice).

Where we reference that we use your personal information in connection with a request, order, transaction or agreement (or preparing for the same), or to provide you with services that you requested (such as a website), we do this because it is necessary for the performance of an agreement with you. Where we reference that we use your personal information in relation to marketing, improvement or development of our products or services, for reasons of safety and security, or regulatory requirements other than in connection with your agreement or request, we do this on the basis of our or a third party’s legitimate interests, or with your consent.
 

• Access and use of websites or other online services

When entering one of our websites, or using an online service, we will record information necessary to provide you with access, for the operation of the website and for us to comply with security and legal requirements in relation to operating our site, such as passwords, IP address and browser settings. We also collect information about your activities during your visit in order to personalize your website experience, such as recording your preferences and settings, and to collect statistics to help us improve and further develop our websites, products and services. For more details, please see below chapter “SPECIFIC INFORMATION ABOUT THE WEBSITE”.
 

• Use of Information in the Social Media Environment

Kontron may provide social computing tools on some of its websites to enable online sharing and collaboration among members who have registered to use them. These include forums, wikis, blogs and other social media platforms. These applications and tools may also include supplemental privacy statements with specific information about collection and handling practices. Read those supplemental statements to understand what the tools and applications may do. Any content you post, such as pictures, information, opinions, or any other type of personal information that you make available to other participants on these social platforms or applications, is not subject to this Privacy Statement.
 

• Recruitment

In connection with a job application or inquiry, whether advertised on a Kontron website or otherwise, you may provide us with information about yourself, such as a resume. We may use this information throughout Kontron in order to address your inquiry or consider you for employment purposes.
 

• Employee Data

In connection with your employment, you may provide us with information about yourself, such as a resume. We use all necessary data communicated for contract execution and if necessary, additional data for processing solely on the basis of your express consent or a prevailing interest does exist. We may use this information throughout the employment period and store the personal data thereafter solely as long as required by law (usually 10 years). External service providers or other contractors, that we hire to support us with taxes, company cars or staff training, may have access to your personal data.

• Investor Relations

The information we processes from shareholders is the name, surname and address of the shareholder as well as the number of shares held by the shareholder. This information is only being used to service the shareholder accounts, to send shareholders company relevant information such as invitations to the annual general meeting, annual reports, proxy statements or other information about the company, in some cases required by law. We may disclose shareholder information to certain third parties as authorized and if the shareholder requests or authorizes the disclosure of the information as permitted by law. For example, the permitted sharing of information with companies who maintain or service shareholder accounts for us. This service is essential for us to provide shareholders with necessary or useful services with respect to their investment, such as record keeping, processed trades and mailing information. We do not disclose, and do not reserve the right to disclose, any nonpublic personal information about our shareholders to any affiliates or nonaffiliated third parties, except disclosures in the ordinary course of business, such as to process transactions, maintain accounts, respond to court orders and legal investigations. We restrict access to nonpublic personal information about shareholders solely (i) to those service providers who need to know that information to provide products or services to shareholders, (ii) to authorized employees of the adviser who need to know shareholder information, or (iii) as otherwise required by law.

Sharing of Personal Information

As a global organization offering a wide range of products and services, with business processes, management structures and technical systems that cross borders, Kontron has implemented global policies, along with standards and procedures, for consistent protection of personal information. As a global company, we may share information about you with our subsidiaries world-wide and transfer it to countries in the world where we do business in accordance with this Privacy Statement. Between Kontron controlled subsidiaries we only grant access to personal information on a need-to-know basis, necessary for the purposes for which such access is granted. When selecting our suppliers and partners, we take into account their data handling processes. If Kontron decides to sell, buy, merge or otherwise reorganize businesses in some countries, such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is Kontron's practice to require appropriate protection for personal information in these types of transactions. Please be aware that in certain circumstances, personal information may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your personal information to protect the rights or property of Kontron, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.

International Transfers

The Personal data is processed at our operating offices of the Kontron Group and in any other places where the parties involved in the processing are located. The international footprint of Kontron involves transfers of personal information between different subsidiaries, as well as to third parties located in the countries where we do business. Some countries have implemented transfer restrictions for personal information, in connection with which Kontron takes various measures, including: where required, Kontron implements Standard Contractual Clauses approved by the EU Commission, or similar contractual clauses in other jurisdictions. This may also include transfers to suppliers or other third parties, if any. You can request a copy of the EU Standard Contractual Clauses.

Retention Period

We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where we do business. Because the circumstances may vary depending on the context and the services, the information provided in a specific notice may provide more detailed information on applicable retention terms. We may be allowed to retain Personal data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. E.g.:

Your registration information for Kontron Customer Section will be retained for as long as your account is active. If you wish to request that we no longer use your registration information to provide you services, please contact us.

Your job application will be stored for the period of the application process and will be deleted latest after 4 months after the recruitment process is finished for the position you applied for or within four months after our communication of a decision to you, unless consent has been given for a longer period of data storage.

Once the retention period expires, Personal data will be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

SPECIFIC INFORMATION ABOUT THE WEBSITE

The following Privacy Statement applies to Kontron websites that link to this Statement but does not apply to those Kontron websites that have their own Privacy Statement.

As mentioned above, we collect information from your visits to our websites and your use of our services to help us gather statistics about usage and effectiveness personalize your experience, tailor our interactions with you, and improve our products and services.

We do so through the use of various technologies, including "cookies". The Data is e.g. collected for the following purposes: remarketing and behavioral targeting, advertising, registration and authentication, analytics, displaying content from external platforms, interaction with external social networks and platforms, interaction with live chat platforms, content performance and features testing (A/B testing), infrastructure monitoring and platform services and hosting.

Users can find further detailed information about such purposes of processing and about the specific Personal data used for each purpose in the respective sections of this document.

A cookie is a piece of data that a website can send to your browser, which may then be stored on your computer as a tag that identifies your computer. While cookies are often only used to measure website usage (such as number of visitors and duration of visit) and effectiveness (such as topics visitors are most interested in) and to allow for ease of navigation or use and, as such, are not associated with any personal information, they are also used at times to personalize a known visitor's experience of a website by being associated with profile information or user preferences. Over time this information provides valuable insight to help improve the user experience.

Cookies are typically categorized as "session" cookies or "persistent" cookies. Session cookies help you navigate through the website efficiently, keeping track of your progression from page to page so that you are not asked for information you have already provided during the current visit, or information needed to be able to complete a transaction. Session cookies are stored in temporary memory and erased when the web browser is closed. Persistent cookies on the other hand, store user preferences for current and successive visits. They are written on your device's hard disk, and are still valid when you restart your browser. We use persistent cookies, for example, to record your choice of language and country location.

When visiting our websites or online services, you may have the possibility to set your preferences regarding cookies and other similar technologies by using the options and tools made available to you by either your web browser or Kontron.

You can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser. Look under the heading "Tools" (or similar heading) in your particular browser for information about controlling cookies. In most instances you can set your browser to notify you before you receive a cookie, giving you the option to decide whether to accept it or not. By clicking 'cookie preferences' at the footer of an Kontron website you can choose and change at any time which types of cookies you would like our websites to use. Using the cookie preferences does not result in deletion of cookies that are already on your device. You can delete cookies already on your device via the settings of your web browser.

For technical reasons, each time your internet browser accesses our website it automatically sends information to our web server (i.e. log data). We store some of this information in log files, such as:

    The date of the access

    The time of the access

    The URL of the linking website

    The files accessed

    The volume of data transferred

    The browser type and version

    The operating system

    The IP address (anonymized)

Log data does not contain personal data. As a general rule, we only analyse log data in order to remedy faults in the operation of our website or clarify security incidents. We store this log data indefinitely. It is sometimes necessary for us to collect additional personal information as well as log data in order to remedy faults or preserve evidence relating to security incidents. In these cases, we are permitted to process the log data by law (article 6(1f) of Regulation (EU) 2016/679). We delete this data once the fault has been remedied or the security incident has been clarified in full, or if the original purpose of the processing no longer exists due to other factors. In the event of a security incident, we will transmit log data to the investigating authorities on a case-by-case basis, to the extent permitted. We always store log data separately from other data collected that relates to the use of our website.

Use of Marketing Automation Software

We use marketing automation software ClickDimensions to record and evaluate the tracking profile of website visitors.
When you visit our websites, the marketing automation software records your click path and uses this to create an individual tracking profile under a pseudonym. Cookies that allow your browser to be recognized are used for this purpose. We may collect information relating to your use of our websites. We may log certain information that your browser sends us, such as your IP address (including information deriving from your IP address such as your geographic location), browser type, version, access time, duration of access; we may also collect information about the pages you view within our sites, the time you spent on each site and other actions you take while visiting our website.
You can deactivate the creation of anonymous usage profiles at any time by configuring your Internet browser so that it does not accept cookies.
The tracking profiles created by our software are not merged with data about the holder of the pseudonym without your explicit consent.
If you give us your consent by activating the checkbox provided for this purpose, you consent to the following collection, processing and use of your personal data:
“I hereby consent to my personal click path on the website of Kontron AG being recorded and to it being collected, processed and used together with my personal information from the contact form. The aforementioned information will be recorded in a central database and will only be used for the purpose of individual information and consultation as well as for market research purposes.”
You may revoke your consent at any time, effective for the future. To do so, please send a mail to datenschutz@kontron.com.
 

Use of Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies,” text files that are stored on your computer and that allow an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the US and stored there. However, in the event IP anonymization is activated on this website, your IP address will be shortened beforehand by Google within member states of the European Union or in other signatory states to the Treaty on the European Economic Area. The full IP address will be transmitted to a Google server in the USA and shortened there only on an exceptional basis. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services to website operators relating to website activity and Internet usage. Google will not associate the IP address transmitted under Google Analytics by your browser with other data held by Google. You may prevent the storage of cookies by selecting the appropriate settings on your browser software; however, we should inform you in this case that you might not be able to enjoy all of the functionality of this website to its full extent. You may additionally prevent the recording of the data (including your IP address) to Google that is generated by the cookie and that pertains to your use of the website, or the processing of these data, by downloading and installing the following browser plug-in available through the following link. In view of the discussion about the use of analytics tools with full IP addresses, we would like to point out that this website uses Google Analytics with the extension “_anonymizeIp()” which means that IP addresses are used only in a shortened form in order to prevent any direct correlation to specific persons. For browsers on mobile devices, please click this link to, in future, prevent anonymous tracking by Google Analytics and to activate a so-called “opt-out cookie” for your browser.

Google AdWords Conversion Tracking  and Remarketing

This website uses Google AdWords Conversion Tracking, a web analytics service provided by Google Inc. (“Google”). Google AdWords Conversion Tracking also uses “cookies” stored on your computer that allow analysis of your use of the website. The information generated by the cookie about your use of this website is transmitted to a Google server in the US and stored there. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services related to website activity and internet usage. Google may also transfer this information to third parties if required by law or in so far as third parties process this data on behalf of Google. Google will in no case connect the data with other data from Google. You can generally prevent the use of cookies by prohibiting the storage of cookies in your browser.

Google MapsAPI

This site uses the Google Maps map service via an API. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. The use of Google Maps is in the interest of making our website appealing and to facilitate the location of places specified by us on the website. Google may transfer the information obtained from Google Maps to third parties, if required by law or as far as third parties process this data on behalf of Google. Google will not associate your IP address with other Google data. Nevertheless, it would be technically possible that Google could make an identification of at least individual users on the basis of the data received. It is possible that Google's personal information and personality profiles could be processed by Google's users for other purposes that we have no control over. You have the option to disable the service of Google Maps and thus prevent the transfer of data to Google by disabling JavaScript in your browser. We point out, however, that in this case you cannot use the map display on our pages. Further information about handling user data, can be found in the data protection declaration of Google at https://www.google.de/intl/de/policies/privacy/.

Google Webfonts

For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly. For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. If your browser does not support web fonts, a standard font is used by your computer. Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at

https://www.google.com/fonts#AboutPlace:about

https://www.google.com/policies/privacy/

Google Site Search

Google Site Search is a search engine embedding service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages. Google Inc. may collect usage data. Place of processing is United States. Further information about handling user data, can be found in the data protection statement at https://policies.google.com/privacy

YouTube video widget

YouTube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages. Usage Data is collected. Place of processing is in the United States. Further information about handling user data, can be found in the data protection statement at https://www.youtube.com/static?template=privacy_guidelines

LeadLander

This site uses a third party application from so called Upland LeadLander.com to track users’ IP addresses and search-related data in order to evaluate visits to, and monitor use of, the Site. The information generated by the cookie about your use of this website is transmitted to a server in the US and stored there. We use the information to compile reports and to help us improve the Site. These anonymous cookies, provided by leadlander.com, help us to measure the effectiveness of our marketing campaigns. This helps us to ensure we are broadcasting the correct mesage in our marketing collateral and to optimize the process of obtaining the information you require.  LeadLander may associate a user’s IP address with a user’s company affiliation, but does not associate any user’s IP address with the user’s name or email address. LeadLander will place a cookie containing a random number called “trackalyzer” on the user’s computer. The random number and the user’s IP address is stored in LeadLander’s external database. LeadLander will honor “Do Not Track” requests if set on a user’s browser. LeadLander does not retain any user or visit data in web logs or log files, but uses pixel tag images to record which pages of the Site are visited. This cookie is persistent so that data can be linked over multiple sessions. LeadLander’s privacy policy can be viewed at https://www.leadlander.com/privacy.html.
 

Uptime Robot (Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.)

Uptime Robot is a monitoring service provided by Buzpark Bilisim Tarim Urunleri Sanayi Tic. Ltd. Sti.. Personal data collected: various types of Data as specified in the privacy policy of the service. Place of processing: Turkey – Privacy Policy.

Use of our own “cookies”

This website uses its own “cookies” to increase user-friendliness (“cookies” are text files sent by the web server to the user’s browser and stored there for later retrieval). Our own “cookies” never store any personal information. You can prevent the use of “cookies” in general if you set your browser to disallow the storage of “cookies.”

Links to Non-Kontron Websites and Third-Party Applications

To allow you to interact with other websites on which you may have accounts (such as Facebook and other social media sites) or join communities on such sites, we may provide links or embed third-party applications that allow you to login, post content or join communities from our websites. We may also provide you with general links to non-Kontron websites. Your use of these links and applications is subject to the third parties' privacy policies, and you should become familiar with the third-party sites' privacy policies before using the links or applications. Kontron is not responsible for the privacy practices or the content of those other websites. 

Handling of business cards

When handing over or exchanging business cards, you provide us with personal data, such as telephone number and email address. We use this information exclusively to keep in touch with you. In addition, we will provide you with further information about our services. If you do not buy any products or services from our range, we will delete your contact details after 5 years.

You have the right to information, deletion or correction at any time.

Information about other data processing procedures

Specific information about the application process

Specific information for the processing of customer data/prospective parties’ data

Specific information on the processing of employee data

Specific information for the processing of supplier data

Specific information on the use of video conferencing/webinar software

Your Rights

You can request to access, update or correct your personal information. If your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information. In the event you consider our processing of your personal information not to be compliant with the applicable data protection laws, you can lodge a complaint.

Any requests to exercise of your rights can be directed to us through the contact details provided in this document, e.g. an e-mail to: datenschutz@kontron.com. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.

Your right to information about your data

We will provide you with information about the data we hold about you on request.

Your right to correct and complete your data

We will correct inaccurate information about you if you notify us accordingly. We will complete incomplete data if you notify us accordingly, provided this data is necessary for the intended purpose of processing your data.

Your right to delete your data

We will delete the information we hold about you on request. However, some data will only be deleted subject to a defined period of retention, for example because we are required to retain the data by law in some cases, or because we require the data to fulfil our contractual obligations to you.

Your right to have your data blocked

In certain legally determined cases, we will block your data if you would like us to do so. Blocked data is only further processed to a very limited extent.

Your right to withdraw consent

You can withdraw consent given for your data to be processed with effect for the future at any time. The legality of processing your data remains unaffected by this up to the point at which your consent is withdrawn.

Your right to object to the processing of your data

You can object to the processing of your data with effect for the future at any time, if we are processing your data on the basis of one of the legal justifications set out in article 6(1e or 1f) of Regulation (EU) 2016/679. In the event that you object we will cease processing your data, provided that there are no compelling and legitimate grounds for further processing. The processing of your data for the purposes of direct marketing never constitutes compelling and legitimate grounds for us.

Your right to data portability

At your request, we can make certain information available to you in a structured, commonly used and machine-readable format.

Your right to appeal to a regulatory authority

You can lodge an appeal pertaining to data protection with a data protection authority. To do so, contact the data protection authority responsible for your place of residence or the data protection authority under whose jurisdiction we fall (named below).

Bavarian Data Protection Authority (BayLDA), www.baylda.de

Changes to our Privacy Statements

From time to time we may update this Privacy Statement, as well as any other specific privacy statement. When making changes to this Privacy Statement, we will add a new date at the top of this Privacy Statement.