Privacy Policy

What this Privacy Policy covers

League Inc. (“us”, “we”, “our”, “League”) is committed to protecting your data, and our highest priority is keeping your sensitive information—especially your personal health information—safe. In this policy we explain what data we collect about you and how we store, analyze, and share the data through League’s website and its mobile and web applications (collectively, “League Platform”, “Platform”).

Nothing in this Policy limits your rights under applicable laws, including your ability, depending on your country of residence, to file a complaint with your local data protection authority.

Please carefully read through this Policy. To join and enjoy League’s Platform and its Services, you are required to accept all terms of this Policy. By using or accessing the League Platform and Services, you are accepting the terms of this Privacy Policy and League’s Terms of Service, and you are consenting to our collection, use, disclosure, and retention of your information as described in this Privacy Policy. If you do not consent to the collection, use, disclosure, and retention of your information as described in this Policy, you will not be able to use the Platform.

Unless otherwise defined herein, capitalized terms shall have the meanings assigned to such terms set forth in the Terms of Service, which incorporate this Privacy Policy by reference.

Applicability of this Privacy Policy

This Privacy Policy is only applicable to the information that we collect about you (hereinafter referred to as “Personal Information” or “Information”) through your interaction with the League Platform and Services, and does not apply to any other third-party website or service that you may be able to access through League’s Platform or any website or digital services of League’s business partners, each of which may have data collection, storage, and use practices and policies of their own that may differ from this Policy. We are not responsible for the actions or privacy practices of these third-party websites or services nor does it signify our endorsement of such websites, locations, or their contents. Please consult those websites and services directly to understand their privacy practices. Your use of the League Platform is governed by this Privacy Policy and the Terms of Service.

For more detail on how we collect and use personal information during the process of applying to work at League, please refer to our Applicant Privacy Notice.

What Information does League collect about me?

We collect Information about you when you provide it to us, when you use our Platform or access our Services, and when other sources provide it to us, as described below. Please note that for purposes of clarity and ease of description, any reference in this Policy to Personal Information or Information should be understood to include each of the categories mentioned below, except where expressly noted or where context clearly implies otherwise.

Personal Information you provide to us

“Personal Information” is any information about you as an identifiable individual. The information we may collect from you includes:

• Your first and last name, home address, and phone number
• Your gender and date of birth
• The email address you use to sign-in and communicate with us
• Other log-in information such as your password or two-factor authentication (2FA) parameters
• Information about your profession including your employee ID, income, role, and employment status
• Your dependents (if any) and their information
• Information about your participation and performance in Health Programs, Challenges, or other activities on the Platform
• Any information you provide to us while interacting with a customer care agent
• Text, image, audio, or video files you provide or upload to the Platform
• The comments and contributions you may make on the Platform
• Any opinions or feedback you may share with us
• Additional information you may provide as you submit queries and requests to us.

“Health Information” is information related to your physical and mental health as well as medical history, including symptoms, conditions, illnesses, diagnoses, procedures, outcomes, and claims submissions. When using League’s Platform you may provide certain health or health-related information to us including through text, image, audio, and video files or other documents you upload through the Platform. Health Information includes:

• Insurance data such as insurance carrier, plan, group, or member ID as well as claims information or history, if you opt in to share this data with League
• Identifiers connected to your health benefits and group plan membership such as Social Security Numbers (U.S.) and Social Insurance Numbers (Canada)
• Any health or health-related information you provide to us while interacting with a customer care agent
• Information concerning your health or health care when you submit a claim towards your benefit spending accounts through the Platform
• Information about your health, fitness, nutrition, and finances provided by you through Health Profile
• Information shared on the Platform through wearable devices and/or applications that you choose to connect to your account.

“Payment Information” is data related to your bank account or e-transfer details. We may collect your bank account and billing information, if you choose to share this data with us, in order to process your spending account claims. By linking your bank account to your League account, you authorize us to submit your Payment Information to the financial institution that will process your employee benefit payment on your behalf.

Personal Information we obtain from others

Employment and benefit information

We may also get Information about you from other sources. For example, we may get employment information from your employer or insurance carrier to enroll you in your health benefits and our Platform. Depending on what your employer shares with us, the data set may include any of your first and last name, employee ID, income, role, employment status, and dependent information. While you are a user of the Platform, we may receive additional employment or benefit information from your employer or insurance carrier including claims data. We might add this Information to your account. Please note that we will only use the Information necessary to enroll you in your benefits and our Platform and to provide you with a  personalized experience through Services such as Health Profile, Health Programs, and Challenges.

Devices and Third Party Apps

As a user of the Platform you may be able to connect activity and health trackers (“Devices”) or other third-party applications (“Third Party Apps”) to your account. These Devices and Third Party Apps can track a wide number of different aspects of your daily activities, including, among others, your daily steps and fitness activity as well as your nutrition. The data we collect may vary depending on the brand and model of tracker you use. In general, Devices and Third Party Apps have their own independent privacy policies that outline what data they collect from you. In some cases you may be able to control what data collected by a Device or Third Party App you wish to share with the League Platform. We strongly suggest you review the relevant privacy policy to know what specific data your Device or Third Party App collects about you.

Social media account information

If you create your League account using a social media account (e.g. Google, Facebook) instead of a unique login or user name, we may also collect Information provided to us by that social media service. This Information may include your name, email address, language preference, and profile picture.

Information we collect automatically when you use the Platform

Device and connection information

We collect Information about your computer, phone, tablet, or other devices you use to access the Platform. This Information includes your connection type and settings when you install, access, update, or use our Platform. We also collect Information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use this additional Information to enhance the security controls around Platform access and resolve bugs and errors that may exist on the Platform. In some cases, we may use your IP address and/or country preference to approximate your geographic location so we can provide you with a better Platform experience.

Cookies and other tracking technologies

We collect Information about you when you use or take certain actions on our Platform or browse our website. To do so, we use cookies and other tracking technologies (e.g., web beacons, device identifiers, and pixels) to provide functionality and to recognize you across different parts of our Platform. For more information, please see our Cookies and Tracking Notice, which includes information on how to control or opt out of these cookies and tracking technologies.

How does League collect my Information?

League receives employment information from your employer or insurance carrier so we can set up your profile and prepare your account for enrollment. Thereafter, we collect Information when you sign-up for League’s Platform and as you submit Information through your use of the Platform and as provided by your employer or insurance carrier.

Depending on the Services that employer has subscribed to on the League Platform for you to access, and the Third Party App or Device integrations you choose to enable and connect to your account, we may collect and receive Personal Information through your use of the particular Services and integrations. These integrated services and solutions may have their own and separate consent process required prior to you using them with League.

How does League use my Information?

How we use the Information we collect depends in part on which Services are offered to you and that you use, how you use them, and any preferences you have communicated to us concern. Below are the specific purposes for which we use the Information we collect about you.

For enrollment and decision support

We guide you through the benefit plan enrollment process so that you can understand your options and choose a level of coverage that meets your needs. To do so, we gather the Information we have received from your employer about you and apply eligibility rules to facilitate your enrollment into your health benefits as well as any other benefit spending accounts offered to you through your employer.

For a personalized Digital Wallet

Through the “Digital Wallet” feature of the League Platform, we provide you with a single, easily-accessible place to manage your plan coverage, eligible dependents, and benefit spending accounts.

For processing your claims

If you are being offered additional benefit spending accounts by your employer through the League Platform, you can submit eligible claims electronically through the Platform. In order to administer these claims and reimburse your bank account, we process the Information provided to us in your claim submission together with the Payment Information we have on file.

For Customer Care services

Through the Platform you have real-time live chat support for your benefit-related questions. To answer your request and to provide you with personalized recommendations, our customer care agents access your Personal Information on file and may in some cases ask you to provide us with additional Information. The additional Information requested of and provided by you may include Health Information.

For health and wellness assessments

You may have access to the Platform’s health assessment feature (“Health Profile”). By asking you a number of questions related to your health and health objectives, the Health Profile assesses your overall well-being across a number of dimensions. You don’t have to complete the Health Profile if you don’t want to share this Information with us.

For creation or enhancement of your personalized Health Programs

As a user of League’s Platform you have access to a central place for your Health Information, personal progress on Health Programs, and any Device and Third Party App integrations you have enabled. League uses Personal Information and Health Information provided to us to help you understand your health risks and long-term outcomes and how you can use your benefits and programs to improve your overall health and wellbeing.

For Challenges

If your employer has subscribed to the “Challenges” feature of the League Platform, your progress in the Challenges you’ve chosen to participate in may be shared with other participants, as well as to HR admins.

For processing appointment bookings and facilitating communications with a Service Provider

When you sign-up for services offered by a Service Provider, we access your Personal Information including your benefit spending accounts. League needs access to this Information to process your appointment booking and facilitate communication between you and the Service Provider.

For safety, security and compliance

We use Information about you and your use of the Platform to identify you as a user, verify accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Platform policies.

To provide the Platform and personalize your experience

We use Information about you to provide and make the Platform available to you, to enhance the security controls around Platform access, and resolve bugs and errors. We may also at times use your Information to verify your geographic location, for example, in order to personalize your experience in the Platform, recommend content, or determine whether the information you request is available in your particular location.

For research and development

We’re always looking for ways to make our Platform smarter, faster, more secure, integrated, and useful to you. We use collective learnings about how people use our Platform and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns, and areas for integration and improvement of the Platform.

To market, promote and drive engagement

If you give your consent, we use your Information to send newsletters, surveys, offers, and promotional materials that may be of interest to you and tailored to your individual health and wellness goals. You can opt out of receiving such messages from League by following the opt-out instructions in these messages. If you opt out, we may still send you other electronic messages of a non-commercial nature related to our operation of the Platform, such as messages about your account, important updates, or our ongoing business relations. Please note that League does not sell or share your Information to third parties for their marketing purposes.

For League Family

Your employer may subscribe to “League Family”, which allows your dependents to use and access the League Platform as well. If this option is available, you can send your dependents (spouse, children, common-law partners) who are eighteen (18) years of age or older an email invitation to join the League Platform and access its Services.

How League shares Information we collect

We may share your Information with third parties so we can provide our Services to you. If we need to share your Information with third parties, we will limit the Information to the minimum amount necessary to ensure the provision and quality of the Services we offer you. We share your Information with third parties as follows:

With contractors

We may disclose your Personal Information with contractors that work on our behalf and assist us in providing and supporting the Services we offer through the Platform.

With Third Party Providers

We share Information with third parties that help us operate, provide, improve, integrate, customize, and support our Platform and Services we offer to you including:

• Cloud hosting services
• Customer service platform
• Connector services and data integration.

If a Third Party Provider requires access to Information about you to perform Services on our behalf, they do so only under instruction from us and in accordance with our internal policies and procedures designed to protect your Information. Our Third Party Providers undergo a thorough security and privacy review as a part of our evaluation process prior to engaging their services and thereafter are subject to regular SOC1, SOC2, NIST, and/or ISO/IEC 27001 audit reviews. In the event that our audits reveal material findings that present a significant risk of harm to League or our clients or users, we work closely with the Third Party Provider to track their remediation efforts until the issue has been resolved.

With insurance carriers

We automatically feed your benefits elections and status/profile updates to your insurance carrier for faster, more accurate enrollment and to determine eligibility or coverage under a benefit plan. When you reach out to us for support about your eligibility or coverage, we may share this Information with your insurance carriers on your behalf.

With your employer

We may share Information with your employer but only in an anonymous and aggregated or group format. Any data sharing practices that go beyond anonymous, aggregated or group format sharing of information requires your explicit prior consent. When sharing de-identified or aggregated information with your employer, we will use procedures compliant with applicable privacy laws and regulations to ensure that all identifiable data and dimensions have been removed from the data sets and reports that we provide. Your employer may, for example, combine the information we provide with other data available to them and use the combined data at their discretion for their own purposes, such as to evaluate the overall program or to make decisions around the provision of specific benefits, programs, and services. Please note we do not control your employer’s use of the data and reports that we provide, and this Policy does not cover your employer’s data use and sharing practices.

With Service Providers

We may share your Information with Service Providers you interact with through the League Platform. When you book an appointment through the Platform, we automatically provide your first and last name along with other Information to the Service Provider. Before we admit any new Service Providers to the Platform, we thoroughly review their practices to make sure they’re in line with our standards. We also regularly review our Service Providers to make sure they stay compliant with their obligations to us.

With Devices and Third Party Apps

You may choose to add new functionality and Information to your account by connecting Devices and Third Party Apps. If you do, you may give these Devices and Third Party Apps access to your account and Information about you like your name and email address, and to any content you choose to share with them. Device and Third Party App policies and procedures are not controlled by us, and this Policy does not cover how Devices and Third Party Apps use your Information. We encourage you to review the privacy policies of third parties before connecting to or using their applications or services to learn more about their privacy and information handling practices. If you object to Information about you being shared with these third parties, please disable connection to the Device or Third Party App within your League account settings.

With law enforcement, governmental authorities, and agencies

We may disclose Information we have collected from and about you—including Personal Information—to different public entities or bodies if we believe in good faith that it’s necessary to:

• Comply with relevant laws or to respond to subpoenas or warrants served upon us
• Enforce our Terms of Service or Privacy Policy
• Protect and defend our rights or property, our customers, our Third Party and Service Providers, or other third parties
• Abide by lawful requests by governmental authorities for the disclosure of Personal Information, including to meet national security or law enforcement requirements.

In the event of a merger, sale, or acquisition

In the event that League undergoes a corporate reorganization or is sold to a third party, any Personal Information we hold about you may be transferred to the re-organized entity or third party, in accordance with applicable laws and regulations. If an event like this occurs, the new entity will continue to use your Personal Information within the limits of this Policy, to continue delivering your service.

For League Family primary account holders

If you are the primary account holder and have dependents using League Family, all of the following will be private and not accessible by your dependents without your explicit consent:

• Usage of your benefits
• Usage of Health Programs and third-party providers through the League platform
• Details of your spending account transactions and balances
• Claims submitted electronically through the League Platform 
• Chats (usage and records) with one of League’s customer care agents 
• Health journey and goals, including Health Profile and recommendations.

Please note that some aggregated/non-personal data may be shared between connected League Family accounts such as between the primary account holder and a dependent account or among dependent accounts. The data shared may include things like the balance of a shared spending account, joint deductibles, and aggregate out-of-pocket spending.

Is my Personal Information and other data secure?

At League, we take security and privacy very seriously. We’re committed to protecting your data, and our highest priority is keeping your sensitive information—especially your personal Health Information—safe. We follow strict security and compliance standards not only because we need to meet specific regulations or legal requirements, but because we consider it one of the most important things we can do for you.

Security is at the heart of every process and every technology we use across all our teams at League. The League Platform is regularly audited to make sure it complies with security, availability, and confidentiality requirements for managing client and user data.

Communication with League should always be done through the League Platform where the Information is secured through encryption and other mechanisms. While League makes every effort to secure all communications within our control and in our Platform, unfortunately no method of delivery can be absolutely secure and there is always a risk that communications of Personal Information may be accidentally or deliberately intercepted by third parties. No company, including League, can fully eliminate every security risk associated with your Information. While we strive to protect your Information, we cannot guarantee its security absolutely.

To help protect yourself and your Information, choose a unique password for our Platform and do not use a password that you would use on any other website or online service. You are responsible for the security of your Information that you transmit to us or view, download, or otherwise access when using public or otherwise unsecured networks. If you use a mobile device to accept a two-factor authentication code, you should have the ability to remotely wipe your device in the event that it is lost or stolen.

Who at League has access to my Information?

Your Personal Information is maintained on League’s infrastructure or those of third-party providers. For that reason, League employees and contractors have access to your Information so we can provide you with high quality Services, including customer care or user technical support. Our employees and contractors are obligated to respect the confidentiality of your Personal Information and are only authorized to access your Information as necessary to provide you with Services or support.

In the event that League undergoes a corporate reorganization or is sold to a third party, any Personal Information we hold about you may be transferred to the re-organized entity or third party, in accordance with applicable laws and regulations. In the event of an acquisition, the new entity will continue to use your Personal Information within the limits of this Policy, to continue delivering your service.

Can I correct or update my Information?

Yes. If your Personal Information changes over time or you realize your Information is outdated or incorrect, you have a right to be able to update or correct it. You may update or correct the Information by changing it right on the Platform. If you aren’t able to update or correct the Information right in your account, you can reach out to a customer care agent through the Platform’s chat function. Alternatively, you can also contact us at help@league.com to request that we update or correct the Information for you. We will respond to your request diligently and within any timeframes prescribed by law.

Can I find out what Information League has collected about me?

Yes. Except in specific circumstances identified by local privacy laws, all users—no matter where they live— have a legal right to access the Information we have collected about them and to be provided with an accounting of its use and disclosure. You can request a copy of all the Information and data we hold about you. We’ll give you a copy of the data in a standard format through a secure channel. To make this request, reach out to us at help@league.com. We will respond to your request diligently and within any timeframes prescribed by law.

For California residents only

As a resident of California, in accordance with the California Civil Code Section 1798.83, you may contact us at the address below to request certain information concerning our disclosure of your Personal Information to third parties for their direct marketing purposes.

Can my Information be deleted?

Yes. Please note, however, that we may not be able to delete your Information without deleting your user account in its entirety. You may request the deletion of your Information or account at any time by submitting a deletion request to help@league.com. Once your account has been deleted, you will no longer be able to access or use your health and wellness benefit accounts offered through the League Platform as well as Services like Digital Wallet, Health Programs, and Challenges.

Please note that we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To decide on the appropriate retention period for Personal Information, we take each of the following factors into consideration:

• The amount, nature, and sensitivity of the Personal Information
• The potential risk of harm from unauthorized use or disclosure of your Personal Information
• The purposes for which we process your Personal Information, and whether we can achieve those purposes through other means
• Applicable legal requirements including regulatory retention periods.

Can I request that League restrict processing for some of my Information?

Because of the types of Services we offer through the Platform, we can’t always accommodate requests to restrict the processing of your Information to certain subsets or purposes only. However, you will be able to limit the Information added to your profile based on your use of Services and participation in Digital Wallet, Health Programs, or Challenges, the Devices and Third Party Apps you choose to connect to your account, and the consent you provide for any data sharing practices. If you want us to stop processing parts of your Information, you can submit an account deletion request through the process outlined above. You can also limit the Personal Information provided to us as you participate in the Services offered to you on the Platform.

If you have connected any Devices or Third Party Apps, you can manage the data sharing and processing setting for each of them through your user account.

If you’ve provided your consent for additional data sharing, you can withdraw your consent at any time. To do so, please reach out to a customer care agent through the Platform’s chat function or by contacting help@league.com.

If you provide your consent, we use your Information to send newsletters, surveys, offers, and promotional materials that may be of interest to you and tailored to your individual health and wellness goals. You may opt out of receiving such messages from League by following the opt out instructions in these messages. If you opt out, we may still send you other electronic messages of a non-commercial nature related to our operation of the Platform, such as messages about your account, important updates, or our ongoing business relations.

Where is my Information being transferred?

League is headquartered in Canada, has an office in the United States, and uses Third Party Providers in these and other countries. Your Personal Information may therefore be transferred to Canada, the United States, or other locations outside of your state, province, country, or other governmental jurisdiction where the local privacy laws may not be as protective as those in your jurisdiction. League takes appropriate steps to protect your privacy and implement reasonable security measures to protect your Personal Information in storage and transmission. We also enter into contracts with our Third Party Providers that require them to treat Personal Information in a way that’s consistent with this Policy and local privacy laws.

I am using League Family as a dependent – What do I need to know?

This is for individuals using League Family as a dependent of the primary account holder. You can expect the same level of privacy and protection of your Information that the primary account holder receives as this Privacy Policy applies equally to you, except for the following differences:

• You will not need to provide any information about your employment
• You will not have the option to provide dependent information
• You will not be able to view any of the above information of the primary account holder or other dependents without their explicit consent
• All of the following will be private and inaccessible by the primary account holder or other dependents without your explicit consent:
  • Usage of your benefits
  • Usage of Health Programs and third-party providers through the League platform
  • Details of your spending account transactions and balances
  • Claims submitted electronically through the League Platform 
  • Chats (usage and records) with one of League’s customer care agents  
  • Health journey and goals, including Health Profile and recommendations.

As with the primary account holder, please note that some aggregated/non-personal data may be shared between connected League Family accounts such as the balance of a shared spending account, joint deductibles, and aggregate out-of-pocket spending.

All dependents using League Family must be eighteen (18) years of age or older. Dependents who are under the age of eighteen (18) are not permitted to use or access the League Platform or Services.

I am an EU resident – What do I need to know?

This is for residents of the European Union (“EU”) including the European Economic Area (“EEA”) countries of Iceland, Liechtenstein, Norway, and, where applicable, Switzerland. Our processing of Personal Information of users who are in the EU is governed by the General Data Protection Regulation (“GDPR”). The GDPR requires us to give you certain information about your data and rights:

Personal information

References to “Personal Information” and “Information” in this Privacy Policy are equivalent to the term “personal data” governed by the GDPR.

Data Controller

League is the data controller of Personal Information provided to, or collected by or for, our Platform and Services. In other cases, we may instead act as a data processor for Personal Information that we process on behalf of your employer when providing the Platform and Services.

Legal basis for processing

We only use or process your Information as permitted by law. We are required to inform you of the legal bases of our processing of your Personal Information, which are described in this Policy. If you have questions about the applicable legal bases for our processing of your Information, reach out to us at privacy@league.com.

Use for additional purposes

We may use or process your Personal Information for reasons not described in this Policy where permitted by law and so long as the reason for the additional processing is compatible with the purpose for which we collected it. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the legal basis.

Cross-border data transfers

Whenever we transfer your Personal Information to countries outside the EU that have not been deemed by the European Commission to provide an adequate level of protection, the transfer will be based on standard contracts approved by the European Commission for such purpose which impose data protection obligations on the parties to the transfer, in this case League and the recipient(s) of your Personal Information. For more details, you may refer to the European Commission Model contracts for the transfer of Personal Information to third countries. Please reach out to us if you want more information on the specific transfer mechanism we employ when transferring your Personal Information to a country outside of the EU.

Your rights to access, correct, restrict, or delete your Personal Information and object to processing

You have the right to request access to your Personal Information, to have your Information corrected, restricted, or deleted, and to object to our processing of your Personal Information. You also have the right of data portability, which means that you can request that we provide you (or a third party you designate) with a transferable copy of the Personal Information that we have collected from you. Your rights may however be subject to various limitations under the GDPR. If you wish to exercise any of these rights, or if you have any concerns about our processing of your Personal Information, please contact us in any of the ways listed in the “Contact Us” section below.

Right to lodge a complaint with a supervisory authority

You have the right to file a complaint about our processing of your Personal Information with your national (or in some countries, regional) data protection authority. The EU Commission has a listing of each country’s designated data protection authority that you can consult here.

Privacy of minors

Individuals under the age of eighteen (18) should not transfer any Personal Information to us or the Platform. We will neither intentionally ask for Information of users under the age of eighteen (18), nor knowingly process any Personal Information of a minor. Only individuals who are eighteen (18) years of age or older are authorized to access and use the Platform and Services.

Additional notice to residents of the United States: League does not intentionally collect or maintain Information from any users of the Platform or visitors to our website who are under thirteen (13) years of age.

Dispute resolution

If you believe that League has not adhered to any aspect of this Privacy Policy, please contact League by email at privacy@league.com. We’ll do our best to make things right. If you feel that your complaint hasn’t been fully addressed, let us know and we’ll investigate further.

If you’d rather file a complaint anonymously, you can do so through our independently operated, whistleblower hotline. You always have the option to remain completely anonymous. Complaints to the whistleblower hotline can be made 24/7/365 through any of the following channels:

• By Phone: 1-866-921-6714 (toll free number in North America)
• By Web Portal: https://www.integritycounts.ca/org/league

For EU Residents: privacy complaints can be lodged with the relevant supervisory authority under the GDPR. Please refer to the “I am an EU resident – What do I need to know?” section above for more details.

Contact US

If you have questions or concerns about this Privacy Policy, please contact us through any of the following means:

By mail at:

Attention: Privacy Officer
League, Inc.
225 King St W, Suite 800
Toronto, Ontario M5V 3M2

By email at: privacy@league.com

Changes to This Privacy Policy

If we make any changes to this Privacy Policy, the updated policy will be posted online together with all past versions and will include the date on which it becomes effective. You may also be notified by email with a summary description of any material changes that are being made to the Policy. Your continued use of the Platform after the effective date of an updated Privacy Policy constitutes your acceptance of its terms. Any updated Privacy Policy supersedes all past versions. Please check back here periodically for updates.

You can find all past versions of our Privacy Policy here.