Privacy Policy
Star Actuarial Futures Limited is committed to protecting your personal data and respecting your privacy, and maintaining the trust and confidence of all of the individuals with whom we interact when carrying out our business.
This Privacy Policy explains when and why we collect your personal data, how we use it, whom we share it with and how we keep it secure. Our Privacy Policy is separated into sections with relevant section headers to make it easier for you to find the parts that interest you.
1. Who we are
Star Actuarial Futures Limited is a private limited company incorporated in Scotland (Company number SC366497). We are registered with the Information Commissioner's Office as a data controller in the United Kingdom (Registration number Z1968466).
2. Summary of this Policy
We collect and use information about you (personal data) in order to carry out our business as a recruitment agency and recruitment business. A brief summary of our processing is set out below. Please see the relevant sections of this policy for more detail.
In summary, we process personal data as follows:
If you are a candidate (or potential candidate) we use your personal data to match you with appropriate opportunities, to find our clients appropriate candidates for their needs, for our own administrative purposes to help us to run our business, and to comply with our legal obligations. For more information about how we collect and use your information see section 3 below.
- If you are a staff member of one of our clients (or prospective clients) then we use your personal data to liaise with you to provide you with our services. For more information about how we collect and use your information see section 4 below.
- If you apply to work with us at Star Actuarial, we use your information to respond to and process your application. For more information about how we collect and use your information see section 5 below.
- If we work with you or have your personal data for other reasons, for example because you provide us with services, we use your personal data in connection with those services and for administrative purposes. For more information about how we collect and use your information see section 6 below.
We keep personal data only for as long as we need it, for example to provide recruitment services or to fulfil our legal or contractual obligations.
We always use appropriate lawful grounds to process your personal data. Our main lawful ground is our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities, on behalf of both the candidates and the organisations which provide the opportunities. However, for some processing activities we will request your consent at the time, and for others we may use other appropriate lawful grounds. We set these out in more detail below.
We respect your data protection rights, including your rights to request access, rectification, restriction, deletion or "porting" of your data, and your right to object to our use of your data. We do not make decisions about you based on electronic profiling activity. We will never sell your personal data.
You can contact us at privacy@staractuarial.com if you have questions about this policy, or about your personal data.
You can contact the UK Information Commissioner's Office (ICO) if you have any concerns. However, we take our obligations seriously, so if you have any questions or concerns, we would encourage you to raise them with us first, so that we can try to resolve them.
3. Candidates
3.1 How we collect your personal data:
We collect your personal data in a number of ways:
- When you register online at www.staractuarial.com, which allows you to upload a CV and allows us to access the information contained within.
- When you register with us over the telephone or in person and you give us information about yourself.
- In the course of contact with you about potential opportunities.
- When you visit our website, we use cookies to help make the experience of using our website better and to personalise the service you receive from us. For more information please see our Cookie Policy.
- In the course of contact with organisations about potentially suitable opportunities.
- From time to time we may obtain data about you from other third parties. This may include referrals from people working in the industry who know and recommend you, other websites where you have uploaded your CV, business networking sites such as LinkedIn, or information from companies providing references, companies providing screening services or other publicly available sources.
3.2 The types of personal data we collect:
We only collect the personal data that is necessary to carry out our business, provide the service you’ve requested, and to keep you informed of potential opportunities.
You can choose not to give us certain information, but this may limit the level of service we can offer. For example, we may not know to contact you about an opportunity that you would be interested in if you have not told us what your sector preferences are, or which location you want to work in.
Information we obtain directly from you:
When you register with us to benefit from our recruitment services, whether online, over the telephone, or in person, and during the course of our relationship with you, we may collect the following information if relevant:
- Prefix and name;
- Gender;
- Email address;
- Date of Birth;
- Contact telephone number(s);
- Address (business, personal or both);
- Skype address;
- Job title;
- Qualification certificates, or other information about your qualifications;
- Remuneration package;
- Copies of your identification documents such as passport or driving licence;
- Copies of relevant work permits;
- Details of your skills, experience and work history, for example as set out in your CV or obtained through discussions with you;
- Details about your job search, including your preferences on job sector and role, and the locations in which you would like to work;
- Records of our correspondence with you;
- Other information involved in the recruitment process, for example information about interviews, copies of your presentations or cover letters;
- If you provide it to us, for example in the context of interview arrangements, we may occasionally receive information from you about your health or disability, which constitutes special category data;
- In rare cases, information about past criminal convictions or proceedings and details of disqualifications.
If you are a contractor with a limited company, we may also collect details about your company, including for example the name of your company, company documentation such as registration details, copies of insurance policies and bank details.
When you visit our website we may collect the following information:
- IP address.
- Cookies: for further information about cookies and how we use them, please refer to our Cookie Policy.
Information from third party organisations
- We may obtain information about you from external sources, or combine the information you have given to us with additional information available from external sources, in the following circumstances:
- We may obtain information about you from third party websites on which you have uploaded your CV, including recruitment websites such as www.theactuaryjobs.com. This may include a combination of information listed above.
- We may obtain information about you from prospective employers, for example information about interview invitations, dates and outcomes, and details of job offers.
- With your permission, we may obtain information about you from companies which provide screening services and from your past employers. This information could include: references; credit checks and criminal record checks.
Information available publicly
- We may obtain information which is already publicly available on third party websites on which you have uploaded your CV, including business networking websites such as LinkedIn. This may include a combination of information listed above.
- Where relevant and proportionate we may collect or cross-check information about you from other sources such as Companies House.
3.3 Why we collect and use your personal data:
The information we hold on you will be used in a number of ways. Our underlying legitimate interest and broad purpose is to operate a business which provides recruitment services, matching candidates with opportunities, on behalf of both the candidates and the organisations which provide the opportunities.
Our purposes and lawful grounds:
- To provide recruitment services to you.
- This is necessary in order to carry out our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- To fulfil our contractual obligations with our clients.
- This is necessary in order to carry out our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- To carry out screening activities and reference checks.
- Where the data is not special category data we rely on the ground that this is necessary in order to carry out our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- Where this involves special category personal data or criminal records data we rely on the combination of this legitimate interest with, as appropriate, one of the following:
- the substantial public interest of equality of opportunity or treatment (for diversity data);
- the substantial public interest of preventing unlawful acts (for right to work information); or
- protecting the public from dishonesty, where certain roles require a criminal records check to be carried out; or
- your explicit consent.
- To ensure that we respect the principles of diversity and equal opportunity.
- Where we process diversity and health data, we rely on our legitimate interest and the substantial public interest to ensure equality of opportunity.
- We may process your health data with your explicit consent in order to ensure that appropriate arrangements are made for you throughout the recruitment process.
- To maintain our internal records.
- This is necessary in order to carry out our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- To obtain advice from our professional advisors.
- This is necessary in order to carry out our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- If any information involved is special category information, we may also rely on the lawful ground that the processing is necessary in order to obtain legal advice.
- To release your personal data to regulatory or law enforcement authorities.
- if we are required to do so by law, or
- if it is necessary in order to carry out our legitimate interest to aid law enforcement.
- To comply with our legal obligations, for example money laundering regulations.
3.4 How we share your data
For the purposes specified above, the information that you provide to us (including any special category personal data as appropriate or as permitted by you) may be shared with:
- our employees;
- our clients (potential or prospective employers) ;
- our service providers;
- our professional advisors;
- regulatory or law enforcement authorities.
We will not share, sell, rent or trade your information with any third parties.
We enter into agreements with the organisations which store or use personal data on behalf of Star Actuarial Futures Limited. They will not use your data for anything other than the clearly defined purpose relating to the service that they are providing to us.
4. Clients
4.1 How we collect your personal data
We collect your personal data in a number of ways:
- When you fill in our "request a callback" form on our website www.staractuarial.com, contact us using our email address or telephone number, or contact any of our employees to enquire about our services and you give information about yourself.
In the course of contact with you or your colleagues during the negotiation for our performance of our services.
When you visit our website, we use cookies to help make the experience of using our website better and to personalise the service you receive from us. For more information please see our Cookie Policy.
From time to time we may also receive data about you from other third parties. This may include the website of your employer and other websites where you have uploaded vacancies, business networking sites such as LinkedIn, or other publicly available sources.
4.2 The types of personal data we collect
We only collect the personal data that is necessary to carry out our business, provide a service you’ve requested, and to keep you informed of suitable candidates that you might find of interest.
Information we obtain directly from you:
When you contact us or when we carry out identity checks to comply with our legal obligations, we may collect the following information if relevant:
- Prefix and name;
- Gender;
- Email address;
- Contact telephone number(s);
- Address (business, personal or both);
- Skype address (if applicable);
- Job title;
- Information about your qualifications;
- Records of our correspondence with you;
- Details of your skills, experience and work history, for example as set out in profiles of biographies provided before you perform candidate interviews;
- We may also collect details about your organisation including the name of your organisation, organisation documentation such as registration details and bank details;
- If you provide it to us, for example in the context of interview arrangements, we may occasionally receive information from you about your health or disability, which constitutes special category data;
- Any other information involved in the recruitment process.
When you visit our website we may collect the following information:
- IP address.
- Cookies: for further information about cookies and how we use them, please refer to our Cookie Policy.
Information from third party organisations
- We may occasionally obtain information about you from third parties, or combine the information you have given to us with additional information available from third parties, for example, candidates whom you have interviewed.
Information available publicly
- We may obtain information which is already publicly available on your organisation's website or on third party websites, including business networking websites such as LinkedIn. This may include a combination of information listed above.
- Where relevant and proportionate we may collect or cross-check information about you from sources such as Companies House.
4.3 Why we collect and use your personal data
The information we hold on you will be used in a number of ways. Our underlying legitimate interest and broad purpose is to operate a business which matches candidates with opportunities, on behalf of both the candidates and the organisations which provide the opportunities.
Our purposes and lawful grounds:
- To provide recruitment services to you.
- We need to use your data in this way in order to carry out a contract with you, or with your organisation.
- If there is no contract in place with you individually, we do this because it is necessary in order to carry out our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- To maintain our business relationship with you.
- This is necessary in order to carry out our legitimate interest to develop our business.
- To maintain our internal records.
- This is necessary in order to carry out our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- To obtain advice from our professional advisors.
- This is necessary in order to carry out our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- If any information involved is special category information, we may also rely on the lawful ground that the processing is necessary in order to obtain legal advice.
- To release your personal data to regulatory or law enforcement authorities.
- if we are required to do so by law, or
- if it is necessary in order to carry out our legitimate interest to aid law enforcement.
- To comply with our legal obligations, for example money laundering regulations.
- We may market to you directly and advise you of any updates to our services, in accordance with our legitimate interest to develop our business. You can ask us to stop doing this at any time.
4.4 How we share your data
For the purposes specified above, we may share your information, as appropriate, with:
- our employees;
- candidates;
- our service providers;
- our professional advisors;
- regulatory or law enforcement authorities.
We will not share, sell, rent or trade your information with any third parties.
We enter into agreements with the organisations which store or use personal data on behalf of Star Actuarial Futures Limited. They will not use your data for anything other than the clearly defined purpose relating to the service that they are providing.
5. Applicants for roles with Star Actuarial
When you apply to work with us at Star Actuarial we treat your personal data as set out in this Privacy Policy. If your application is successful and you become one of our staff members we will process your personal data in accordance with our internal staff Privacy Policy.
5.1 How we collect your personal data
We collect your personal data in a number of ways:
- When you register online at www.staractuarial.com, which allows you to upload a CV and allows us to access the information contained within.
- When you register with us over the telephone or in person and you give us information about yourself.
- In the course of contact with you about potential jobs.
- When you visit our website, we use cookies to help make the experience of using our website better and to personalise the service you receive from us. For more information please see our Cookie Policy.
- From time to time we may also obtain personal data about you from other third parties. This may include websites where you have uploaded your CV, the website of your current employer, business networking sites such as LinkedIn, or information from companies providing recruitment services, screening services or references.
5.2 The types of personal data we collect
We only collect the personal data that is necessary to carry out our business, consider your application, and to keep you informed of potential job opportunities if we think that you are a good match for our organisation but we do not currently have a role available for you.
Information we obtain directly from you:
When you apply for a role at Star Actuarial, whether online, over the telephone, or in person, and during the course of our relationship with you, we may collect the following information if relevant:
- Prefix and name;
- Gender;
- Email address;
- Date of Birth;
- Contact telephone number(s);
- Address (business, personal or both);
- Skype address;
- Job title;
- Qualification certificates, or other information about your qualifications;
- Remuneration package;
- Copies of your identification documents such as passport or driving licence;
- Copies of relevant work permits;
- Details of your skills, experience and work history, for example as set out in your CV or obtained through discussions with you;
- Details about your job search, your preferences on job sector and role, and the location in which you would like to work;
- Records of our correspondence with you;
- Other information involved in the recruitment process, for example information about interviews, copies of your presentations or cover letters;
- If you provide it to us, for example in the context of interview arrangements, we may occasionally receive information from you about your health or disability, which constitutes special category data;
- In rare cases, information about past criminal convictions or proceedings and details of disqualifications;
- If you are a contractor with a limited company, we may collect details about your company, including for example the name of your company, company documentation such as registration details, copies of insurance policies and bank details.
When you visit our website we may collect the following information:
- IP address.
- Cookies: for further information about cookies and how we use them, please see our Cookie Policy.
Information from third party organisations
We may obtain information about you from external sources, or combine the information you have given to us with additional information available from external sources, in the following circumstances:
- With your permission, we may obtain information about you from companies which provide screening services and from your past employers. This information could include: references; credit checks and criminal record checks.
Information available publicly
- We may obtain information which is already publicly available on third party websites on which you have uploaded your CV, including business networking websites such as LinkedIn.. This may include a combination of information listed above.
- Where relevant and proportionate we may collect or cross-check information about you from sources such as Companies House.
5.3 Why we collect and use your personal data
The information we hold on you will be used in a number of ways.
Our purposes and lawful grounds:
- To conduct a recruitment process to find suitable staff for our business.
- We need to use your data in this way for our own legitimate interest to hire suitable staff for our own organisation.
- To carry out screening activities and reference checks.
- Where the data is not special category data we rely on the ground that this is necessary in order to carry out our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- Where this involves special category personal data or criminal records data we rely on the combination of this legitimate interest with, as appropriate, one of the following:
- the substantial public interest of preventing unlawful acts (for right to work information); or
- your explicit consent.
- To ensure that we respect the principles of diversity and equal opportunity.
- Where we process diversity and health data we rely on both our legitimate interest and the substantial public interest to ensure equality of opportunity.
- We may process your health data with your explicit consent in order to ensure that appropriate arrangements are made for you throughout the recruitment process.
- To comply with any other applicable legal obligations.
- To maintain our internal records.
- We need to use your data in this way for our own legitimate interest to hire suitable staff for our own organisation.
- To obtain advice from our professional advisors.
- This is necessary in order to carry out our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- If any information involved is special category information, we may also rely on the lawful ground that the processing is necessary in order to obtain legal advice.
- To release your personal data to regulatory or law enforcement authorities.
- if we are required to do so by law, or
- if it is necessary in order to carry out our legitimate interest to aid law enforcement.
5.4 How we share your data
For the purposes specified above, during the application process the information that you provide to us (including any special category personal data as appropriate or as permitted by you) may be shared with:
- our employees;
- our service providers;
- our professional advisors;
- regulatory or law enforcement authorities.
We will not share, sell, rent or trade your information with any third parties.
We enter into agreements with the organisations which store or use personal data on behalf of Star Actuarial Futures Limited. They will not use your data for anything other than the clearly defined purpose relating to the service that they are providing.
6. Other third parties
6.1 How we collect your personal data
We collect your personal data in a number of ways:
- When you contact us using our email address or telephone number, or contact any of our employees and you give information about yourself.
- In the course of communications with you or your colleagues.
- When you visit our website, we use cookies to help make the experience of using our website better and to personalise the service you receive from us. For more information please see our Cookie Policy.
- From time to time we may also receive data about you from other third parties. This may include other websites, business networking sites such as LinkedIn, or information from companies providing related services.
6.2 The types of personal data we collect
We only collect the personal data that is necessary to carry out our business services or interests, engage you to provide a particular service, to provide you with a particular service you’ve requested, or to comply with applicable legal requirements.
Information we obtain directly from you:
When you contact us or when we carry out identity checks to comply with our legal obligations, we may collect the following information if relevant:
- Prefix and name;
- Email address;
- Contact telephone number(s);
- Address (business, personal or both);
- Skype address;
- Job title;
- Qualification certificates, or other information about your qualifications;
- The fees you charge;
- Copies of your identification documents such as passport or driving licence;
- Copies of relevant work permits;
- Details of your skills, experience and work history, for example as set out in your CV or profile, or obtained through discussions with you;
- Records of our correspondence with you;
- Other information involved in our interactions with you, for example logistics information about our meetings or your provision of services to us;
- If you provide it to us, for example in the context of logistics or administrative arrangements, we may occasionally receive information from you about your health or disability, which constitutes special category data;
- In rare cases, information about past criminal convictions or proceedings and details of disqualifications;
- We may also collect details about your organisation including the name of your organisation, organisation documentation such as registration details and bank details.
When you visit our website we may collect the following information:
- IP address.
- Cookies: for further information about cookies and how we use them, please refer to our Cookie Policy.
Information from third party organisations
We may obtain information about you from external sources, or combine the information you have given to us with additional information available from external sources, in the following circumstances:
- We may obtain information about you from service providers, regulators, candidates or business contacts with whom we work.
Information available publicly
- We may obtain information which is already publicly available on your organisation's website or on third party websites, including business networking websites such as LinkedIn. This may include a combination of information listed above.
- Where relevant and proportionate we may collect or cross-check information about you from sources such as Companies House.
6.3 Why we collect and use your personal data
The information we hold on you will be used in a number of ways. Our underlying legitimate interest and broad purpose is to operate a business which matches job candidates with job opportunities, on behalf of both the job seekers and the organisations which provide the job opportunities.
Our collection and use of your personal data depends on the context and on our relationship with you or your organisation.
Our purposes and lawful grounds:
- To enable you to provide a service to us:
- We need to use your data in this way for our own legitimate interest to obtain the support that we need to operate a business which provides recruitment services, matching candidates with opportunities.
- To fulfil our contractual obligations with you.
- To maintain our business relationship with you.
- We need to use your data in this way for our own legitimate interest to develop our business which provides recruitment services, matching candidates with opportunities.
- To maintain our internal records.
- We need to use your data in this way for our own legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- To obtain advice from our professional advisors.
- This is necessary in order to carry out our legitimate interest to operate a business which provides recruitment services, matching candidates with opportunities.
- If any information involved is special category information, we may also rely on the lawful ground that the processing is necessary in order to obtain legal advice.
- To comply with our legal obligations, for example money laundering regulations.
- To release your personal data to regulatory or law enforcement authorities.
- if we are required to do so by law, or
- if it is necessary in order to carry out our legitimate interest to aid law enforcement.
6.4 How we share your data
For the purposes specified above, the information that you provide to us (including any sensitive personal data as appropriate or permitted by you) may be shared, as appropriate, with:
- our employees;
- our service providers;
- our professional advisors;
- our clients and candidates to whom we provide recruitment services;
- regulatory or law enforcement authorities.
We will not share, sell, rent or trade your information with any third parties.
We enter into agreements with the organisations which store or use personal data on behalf of Star Actuarial Futures Limited. They will not use your data for anything other than the clearly defined purpose relating to the service that they are providing.
7. How we protect your data (including transfers outside of the European Economic Area (EEA))
We take reasonable and appropriate steps to keep your personal data safe using a range of appropriate technical and organisational measures. For example, we utilise encryption, firewalls and ransomware protection.
Please remember that the transmission of information via the internet is not completely secure, although we put measures in place to keep your personal data secure when we are processing it.
We hold your personal data on servers located within the European Economic Area (EEA).
If you apply for a job opportunity with an employer located outside of the EEA, we may transfer your personal data outside of the EEA. In this scenario we will either:
- ask you for your consent before we transfer your personal data, making it clear where your personal data will be transferred to and whether the European Commission has decided that the destination location provides adequate protection for personal data; or
- if we regularly transfer data to the organisation in question, we will seek to ensure that the European Commission's Standard Contractual Clauses are in place.
In addition, it is possible that certain of our clients may transfer your personal data outside of the EEA.
8. How long we keep your personal data
It is our policy to only store your data for as long as is reasonably necessary for the provision of recruitment services to you.
The following sets out certain specific lengths of time we are required by law to retain certain elements of your data:
- for 2 years from the end of your last period of engagement for limited company contractors for the purposes of providing evidence that right to work checks were carried out under The Immigration (Restrictions of Employment) Order 2007;
- for 6 years from the end of each tax year for limited company contractors for the purposes of retaining payroll records under the Income Tax (Employment and Pensions) Act 2003;
- for 6 years from the end of each tax year for the purposes of keeping VAT records for any VAT registered limited company contractors.
However, we may retain these and other data for longer than a 6-year period where we have a legal or contractual obligation to do so, or we form the view that this is in our legitimate interest for the provision of our services.
We review our retention periods for personal data as required and we do not keep more than we need for our purposes.
9. Your rights
You have a right to access your personal data and to request for this to be updated (see section 10 "How you can access and update your information" below).
You also have the rights:
- to ask us to restrict the processing of your data (meaning that we could store it but not use it);
- to object to how we use your data; and
- to request that we delete your personal data.
Our response will depend on the lawful ground we have used to process your personal data and the circumstances in question.
You also have the right to ask us to "port" (transfer in an electronic format) personal data to another service provider if:
- it is stored electronically;
- we received it from you; and
- we are processing it on the grounds of your consent or that it is necessary to process the personal data in order to carry out or enter into a contract with you.
To the extent that we carry out marketing activity, you have the right to opt out at any time using our contact details below. Of course, we will always respect your wishes if you no longer want to hear from us, for whatever reason.
You have the right to complain to the Information Commissioner's Office (ICO). You can contact the ICO at https://ico.org.uk/ or by calling 0303 123 1113. However, we take our obligations seriously, so if you have any questions or concerns, we would encourage you to raise them with us first, so that we can try to resolve them.
10. How you can access and update your information
You can request details of the personal data we hold about you, including a copy, by contacting privacy@staractuarial.com.
Please include a description of the information you would like to see, together with proof of your identity (a copy of your driving licence or passport and a recent utility bill). Please confirm in your email to us that you consent to us using your identity documents in order to check your identity.
We will delete your identification information after we have completed responding to your request.
11. Use of 'cookies' and tracking technology
What are 'cookies'?
'Cookies' are ways of saving a small amount of user information. The actual cookie is a small file of letters and numbers placed by a website onto a user's computer/device when he or she accesses the website.
How do we use cookies?
Cookies enable us to provide the features you are used to in websites, like remembering your job search terms. Our cookies are in place to enable job searching and to optimise your overall experience on the site.
There are three ways our cookies are used:
- To Enable Your Navigation - Like most websites, we use cookies to maintain your 'session' (the time you spend on the site). These aid your navigation around the site and the use of features such as the Job Search. These are ‘session cookies' and will expire (leave your computer/device) when you leave the website.
- ‘Share this’ cookies to share jobs to Facebook/Twitter.
- Cookies for google analytics tracking - We use analytics cookies to help us understand how visitors use our site, what content is most useful to our visitors, and how to make improvements to it.
We don't sell the information collected by cookies, nor do we disclose the information to third parties, except where required by law (for example to government bodies and law enforcement agencies).
How can you opt out?
You can choose to delete your cookies by changing the settings on your internet browser. Please note that if you do this some areas of our website may not function properly, and you will see our cookie banner next time you visit our website.
For more information on how to refuse cookies, please visit the "help" section of your browser or visit www.allaboutcookies.org.
12. Contact us
If you have any questions or concerns, please contact us:
- By email at privacy@staractuarial.com;
- By telephone at +44 (0)20 3393 1880;
- By post at 123 Irish Street, Dumfries, DG1 2PE.
13. Updates to this Privacy Policy
From time to time we may update this Privacy Policy, so please check our website regularly for updates.
This Privacy Policy was last updated on 16 May 2018.