Privacy Policy

STARLIMS Privacy Policy 

This Privacy Policy explains how STARLIMS handles personal information that we collect online, through our websites and applications (apps) and through our offline interactions with you (collectively, the “STARLIMS Services”). This Privacy Policy does not apply to information collected from residents of countries other than the United States, or to third-party websites to which STARLIMS may link. Your use of STARLIMS Services which link to this Privacy Policy are subject to this Privacy Policy and the Terms of Use.

Please read this Privacy Policy before using the STARLIMS Services or submitting personal information to us.

On occasion, STARLIMS may offer apps, special programs, activities, events or promotions (“Programs”) that have unique or additional specific terms, privacy notices and/or consent forms that explain how any information you provide will be processed in connection with the Programs. You should review the applicable terms before interacting or participating in the Programs.

Personal information 

“Personal information” is information that identifies you as an individual or relates to an identifiable individual. Examples of personal information include your name, your postal address and your telephone number.

How does STARLIMS collect personal information?

STARLIMS collects information in a few different ways:

• Information you submit or choose to provide
• Information you give us permission to collect from you or another source
• From Health Care Professionals Through our websites and mobile apps
• From contract research organizations and clinical trial investigators 
• From your participation in STARLIMS programs or clinical trials
• From third party service providers, data brokers or business partners 
• From industry and patient groups and associations
• Automatically from devices you use to connect to STARLIMS Services (See “Cookies and Other Tools” below)
• Information provided by STARLIMS partners
• From public sources including, but not limited to, social media and other websites that enable social sharing
• Information from government agencies, public or third-party information sources

From time to time, we may use or augment the personal information we have about you obtained from other sources, such as public databases, social media platforms and other third parties. We may also combine information we get from a third-party with information we already have, and we may combine information that we have collected offline with information we collect online.

If you choose to submit any personal information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy.

Information STARLIMS collects

STARLIMS may collect the following information, depending on what product and service you use:

• Contact information and preferences (such as name, email address, mailing address, phone number, and emergency contact information)
• Biographical and demographic information (such as date of birth, age, gender, ethnicity, marital status, and sexual orientation) Health and medical information (such as medical insurance details, information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history and medications an individual may take, including the dosage, timing, and frequency) we collect in connection with managing clinical trials, conducting research, providing patient support programs, distributing and marketing our products, managing compassionate use and expanded access programs and tracking adverse event reports
• Information regarding parents or legal guardians
• Any information you provide in connection with applying to or participating in a patient assistance or support program (such as financial need information)
• Payment-related information we need to complete a transaction (such as credit card number and financial account information) Username and password that you may select in connection with establishing an account on our websites or mobile apps
• Your photograph, social media handle or digital or electronic signature
• Publicly available information
• Internet activity, such as your Internet Protocol (“IP”) address, browsing history, your search history and information on your interaction with the STARLIMS Services and our advertisements
• Device information
• Geolocation data, e.g., your physical location or movements (See “Cookies and Other Tools” below)
• Inferences drawn from other personal information listed above, to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes
• If you are accessing STARLIMS websites or apps on your mobile device, you may also choose to provide us with location data. To protect your privacy, you should not provide STARLIMS with any information that is not specifically requested
• Any adverse event information

If you are a Health Care Professional, we may also collect:

• Professional credentials, educational and professional history, institutional and government affiliations, information included on a resume or curriculum vitae, education and work history (such as work experience, education and languages spoken)
• Information about the STARLIMS programs, products and activities with which you have engaged
• Details about our interactions with you, your prescribing of our products and the agreements you have executed with us; including remittance or other financial information
• Any information you choose to provide about yourself or your household
• Information collected in connection with STARLIMS hosted events or activities you attend or participate in
• Publicly-available information related to your practice, such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence related information

We may use the personal information we collect about you with information obtained from other sources, such as public databases, social media platforms and other third parties. For example, we may use public information to confirm contact or financial information, to verify licensure of Health Care Professionals or to better understand your interests by associating demographic information with the information you have provided.

How does STARLIMS use personal information?

How STARLIMS uses your information depends on how you interact with the STARLIMS Services. Generally, STARLIMS may also use your information to:

• Provide our products and services to you and make them better Develop new products and services
• Fulfill your requests Provide customer service
• Send you administrative communications regarding STARLIMS’s products or STARLIMS Services
• Notify you about special promotions or offers that may be of interest to you
• Invite you to participate in surveys about our products or services Better understand the interests of our customers and visitors who use STARLIMS Services
• Maintain STARLIMS’s online services such as websites and apps Monitor, detect and prevent fraud, improper activity and ensure STARLIMS’s policy compliance
• Conduct research including secondary and follow-on research Determine an individual’s eligibility to participate in STARLIMS programs or clinical trials
• Process payments
• Evaluate how you and other users interact with our online services Protect STARLIMS and our users
• Secure our online services including our network, websites and apps Conduct audits related to our current interactions with you
• Debug the site and service to identify and repair errors that impair existing intended functionality
• Defend ourselves in litigation and investigations and to prosecute litigations
• Comply with our legal and regulatory obligations

STARLIMS may also use information collected from you or about you to offer you customized content, including to:

• Recognize new or past visitors to our websites or apps 
• Remember your personal preferences
• Show you more relevant and meaningful advertisements based on your interests

STARLIMS may also use your information for other purposes disclosed to you from time to time.

In addition, some of our applications and mobile-optimized sites may have location-based features. To deliver these features, we may collect and use location data provided by your mobile device. For example, we may offer shopping features that allow you to get information about local merchants. By using such applications, you consent to the collection and use of your mobile device location data for purposes of delivering these location-based features.

We may use personal information collected from any of the sources listed in the “How Does STARLIMS Collect Personal Information?” section of this policy for our internal business purposes, such as data analysis, audits, developing new products, enhancing our websites and apps, improving our STARLIMS Services, identifying usage trends and determining the effectiveness of our promotional campaigns.

We may aggregate and/or de-identify data about customers and site visitors and use it for any purpose, including product and service development and improvement activities.

Does STARLIMS share personal information?

STARLIMS may share your information within the STARLIMS family of companies.

We do not sell your personal information. However, we share personal information with our vendors, contractors, business and service partners, or other third parties (collectively, “Service Providers”). Examples of Service Providers include analysis firms, advertisers, payment processing companies, customer service and support providers, email, IT services and SMS vendors, web hosting and development companies and fulfillment companies. Service Providers also include our co-promotion partners for products that we jointly develop and/or market with other companies.

Some Service Providers may collect personal data on behalf of STARLIMS. These third parties may be provided with access to personal data needed to perform their functions. In addition, STARLIMS’s practice is to require its Service Providers to keep your personal information confidential and to use personal information only to perform functions for STARLIMS.

If STARLIMS sells all or part of one of its product lines or divisions, your information may be transferred to the buyer. STARLIMS reserves the right to disclose your information to respond to authorized information requests from government authorities, to respond to valid judicial requests, to address national security situations, to provide security and investigate potential fraud, or when otherwise required by applicable law.

STARLIMS may also disclose your personal information as required by law to any competent law enforcement body, regulatory or government agency, court or other third party where we believe the disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request or legal process served on us, or to protect the safety, rights, or property of our customers, the public, STARLIMS or others, and to exercise, establish or defend STARLIMS’s legal rights.

STARLIMS may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose.

Cookies and Other Tools

STARLIMS and its Service Providers collect information about you by using cookies, tracking pixels, web beacons and other technologies (collectively, “Tools”). We use this information to better understand, customize and improve user experience with our websites, services and offerings as well as to manage our advertising. This information can make your use of our STARLIMS Services easier and more meaningful by allowing STARLIMS and our Service Providers to provide better service, customize sites based on consumer preferences, compile statistics, provide you with more relevant advertisements based on your interests, analyze trends and otherwise administer and improve our STARLIMS Services. If we have collected your personal information, we may associate this personal data with information gathered through the Tools.

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org.

You can also control Flash cookies which we may use on certain STARLIMS websites and apps from time to time by clicking here:

” target=”_blank”>Adobe – Flash Player : Settings Manager – Website Storage Settings panel (macromedia.com)

Because Flash cookies cannot be controlled through your browser settings. Choices you make are both browser and device-specific.

Here are some of the types of information collected when visiting STARLIMS Websites:

Log data: When you use STARLIMS websites and apps, our servers automatically record information (“log data”), including information that your browser sends whenever you visit an website or app or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the webpages you visited that had STARLIMS features, browser type and settings, the date and time of your request, how you used websites and cookie data.

Cookie data: Depending on how you are accessing STARLIMS’s online Services, we and our Service Providers may use “cookies” (a small text file sent by your computer each time you visit our sites, unique to your STARLIMS account or your browser) or similar technologies, to record log data. When we use cookies, we may use “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you and/or your browser delete them). For example, we may use cookies to remember your personal preferences, such as sections of the website that you visit frequently, your user ID, or other settings so you do not have to set them up every time you visit, and we may use cookies to serve you relevant advertising tailored to your interests. Some of the cookies we use are associated with your STARLIMS account (including personal information about you, such as the email address you gave us), and other cookies are not.

We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the STARLIMS Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy/google-partners, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Social media plugins and data: In addition, our websites and apps may use social media plugins (e.g., the Facebook “Like” button, ‘”Share to Twitter”‘ button) to enable you to easily share information with others. When you visit any of our online STARLIMS Services, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our websites. If you are logged into the social media website (e.g., Facebook, Twitter, Google+) while browsing on our STARLIMS Services, the social plugins allow that social media website to receive information that you have visited our STARLIMS Services. The social plugins also allow the social media website to share information about your activities on STARLIMS with other users of their social media website. STARLIMS does not control any of the content from the social plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.

If you choose to link your social media or Google account to STARLIMS, this allows us to obtain information from those accounts (such as your friends or contacts). The information we obtain from these services often depends on your settings or the applicable provider’s privacy policies, so please check these policies before granting us access. You agree that we are not responsible for any acts or omissions by these social media service providers. If you give us permission to access this information, we will use it for the purposes described in this Privacy Policy.

Device information: In addition to log data, we may also collect information about the device you are using to access our STARLIMS Services, including what type of device it is, what operating system you are using, device settings, unique device identifiers and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. For example, different types of information are available depending on whether you are using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device may make available to us, please also check the policies of your device manufacturer or software provider.

Interest Based Advertising: STARLIMS hopes to deliver to you advertising for products and services you need or want. STARLIMS, its vendors and partners, use common tracking tools, such as cookies, pixels, web beacons, and similar technologies, to automatically collect information about users for purposes of enhancing their online experience and delivering more meaningful advertisements. Like many companies, STARLIMS may also utilize third-party advertising vendors and other partners to collect this information.

Like most companies, we place advertisements where we think they will be most relevant to customers. One way we do so is by allowing network advertising companies with whom we work to place their own Tools when an individual visits STARLIMS websites and apps. This enables the network advertising company to recognize individuals who have previously visited STARLIMS websites and apps and to serve you ads based on your web browsing activity, purchases, interests and/or other information—a practice commonly referred to as interest-based advertising (“IBA”) or online behavioral advertising (“OBA”).

These advertising companies may also use these types of technologies to recognize you across the devices you use, such as a mobile phone or a laptop, and serve you ads on websites you visit and applications you use.

Retargeting: One way in which we deliver more meaningful advertisements is through a common form of online advertising known as “retargeting” or “remarketing.” Retargeting works by serving ads on one site based on an individual’s online activities on a different, unrelated site. For example, if you look for SDMS products on an STARLIMS website, you may later see an advertisement for SDMS products when you visit third-party sites. To do this, STARLIMS or its advertising vendors may use a device ID, cookie, pixel, web beacon or similar technology placed by STARLIMS or our third-party vendor when you visit STARLIMS websites or apps or third-party websites or apps. The placing of these cookies or other technologies on your device may enable you to be identified across multiple websites. You should consult the privacy policies of our vendors and other websites that you visit to understand how they collect and use your data.

Opting-Out of IBA, OBA and Retargeting Activities

As a participant of the Digital Advertising Alliance (DAA), we adhere to DAA’s Interest-Based Advertising principles by providing you enhanced notice, transparency and control of our digital marketing practices as stated at http://www.aboutads.info/principles/. Click here to opt-out of having your online behavior collected for advertising purposes and receiving behaviorally targeted advertisements from our advertising partners. Choices you make are both browser and device-specific. Also, certain versions of the iOS operating system permit you to “ Limit Ad Tracking” in the system settings, and certain versions of the Android operating system allow you to “ Opt-out of Interest-Based Ads” in the system settings.

Options you select are browser and device specific.

STARLIMS Do Not Track Policy. Some browsers have Do Not Track (“DNT”) features that allow you to tell a website not to track you.  These features are not all uniform, and some browsers may not be set up to honor such requests. STARLIMS honors the AdChoice DNT signals. Options you select are browser and device specific. Please be aware that limiting the ability of websites to set cookies, however, may worsen your overall user experience, and in some cases the sites will not work properly without cookies, local storage and similar technologies.

What choices do I have about STARLIMS collects and uses information about me?

Certain STARLIMS Services may ask whether you wish to opt-out or opt into our contact lists for offers, promotions and additional services that may be of interest to you.

Marketing

If you no longer wish to receive promotional marketing materials from us on a going-forward basis, you may opt-out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from STARLIMS by following the instructions included in the email. We will endeavor to comply with your request as soon as reasonably practicable.

However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our Privacy Policy or Terms of Use).

Your Privacy Choices

• You may have certain rights and choices regarding our processing of your personal data. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right (with certain limitations and exceptions) to:
• Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared
• Access a copy of the personal information we retain about you Request deletion of your personal information

We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals or their authorized representatives to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identify. Where we deny your request in whole or in part, we will endeavor to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

We will not restrict or deny you access to our STARLIMS Services because of choices and requests you make in connection with your personal information. Please note, certain choices may affect our ability to deliver the STARLIMS Services. For example, if you sign up to receive marketing communications by email, then ask STARLIMS to delete all of your information, we will be unable to send you marketing communications.

You may exercise any of your rights in relation to your personal information by contacting us using the details provided under the “How Can I Contact STARLIMS” section below.

How does STARLIMS secure information? 

It is STARLIMS’s practice to take steps to secure our STARLIMS Services; however, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your health. STARLIMS cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to STARLIMS websites or apps, you must weigh both the benefits and the risks. STARLIMS websites or apps may link to third-party websites that are not controlled by STARLIMS or subject to an STARLIMS privacy policy.

You should check the privacy policies of such third-party websites before submitting personal information.

This website is not for children

STARLIMS does not knowingly collect or use any information from children (we define “children” as minors younger than 13). We do not knowingly allow children to order our products, communicate with us, or use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below and we will work with you to address this issue.

Third party sites

We may provide links to websites and other third-party content that is not owned or operated by STARLIMS. The websites and third-party content to which we link may have separate privacy notices or policies. STARLIMS is not responsible for the privacy practices of any entity that it does not own or control.

If you provide any personal through a third-party site, your interaction and your personal information will be collected by, and controlled by the privacy policy of, that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this privacy policy.

Cross border transfers

Any information you provide to STARLIMS may be stored and processed, transferred between and accessed from the United States, where STARLIMS is headquartered, and other countries which may not guarantee the same level of protection of personal data as the one in which you reside. However, STARLIMS will handle your personal data in accordance with this privacy policy regardless of where your personal data is stored/accessed.

Data Protection for individuals in the European Union (EU) 

In addition to the above information, as STARLIMS is a global business we may collect data from citizens within the EU.

Through this section of the Privacy Policy, we aim to inform you about the types of personal data we may collect from European individuals, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR.

Transfer Of Information Outside The EEA

Under the General Data Protection Regulation, we are required to tell you if we transfer or intend to transfer information which we hold on you to countries outside the European Economic Area (“EEA”).

Except as prohibited by law, the information that you will provide us with us may be stored on STARLIMS servers outside of Europe and other STARLIMS companies or business partners may process this information on STARLIMS’ behalf, but always under strict conditions of confidentiality. STARLIMS will keep this information to enable it to properly and effectively administer and monitor the customer relationship it has with you. We transfer such information outside the EEA only if:

a) your product or service enquiry is are best handled by one of our companies located outside the EEA; or

b) the service you have requested, such as a newsletter, is delivered through a third-party located outside the EEA.

In either case, a list of companies we may utilize outside the EEA is available upon request by contacting us at [email protected].

We apply equal rigour to the security of data held and processed by us or on our behalf outside of the EEA. We have taken steps to ensure that our subsidiaries and affiliates and those who process data on our behalf enter into the standard contractual clauses approved by the European Commission, to safeguard the personal information which is transferred to and from the EEA and beyond.

As some of our servers are located in the USA, transfer of some of our data outside the EEA is necessary to enable us to operate the Site. To the extent that any personal information is provided to third parties outside the EEA, or who will access the information from outside the EEA, we take steps to ensure that approved safeguards are in place, such as the approved standard contractual clauses or the EU-US Privacy Shield (see our Privacy Shield statement above).

Trusted Third Parties

We will only share your personal information with trusted third parties where we have retained them to provide services that you have requested or for our legitimate business purposes, such as IT or professional support services.

The Legal Basis for Processing your Personal Information

STARLIMS’ Website

The STARLIMS website gathers and processes your personal data only if you actively give it to us. Under the GDPR, the legal basis for processing your personal information is Consent, respectively “legitimate interest”, which can mean you have asked us to provide a service (such as a newsletter) or to contact you using the details you have submitted.

To withdraw your consent, please use the unsubscribe link at the bottom of a newsletter or contact [email protected].

Data Provided to STARLIMS by its customers to fulfill STARLIMS’ contractual obligation

Under our customer contracts, STARLIMS gathers and processes customers’ customers personal data only if provided to STARLIMS in order to fulfill its contractual obligations. Under the GDPR, the legal basis for processing your customers’ personal information is contractual obligation.

How Long We Will Hold Your Information

We will retain your personal information only for the time necessary to provide the Services we perform for you, or stated by the purposes outlined in this Privacy Policy. In particular, we will store certain categories of your personal information for the following periods of time:

If you are unhappy about our use of your personal information, you can contact us using the details in the contact details below. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods:

Telephone: 0303 123 1111

Website: https://ico.org.uk/concerns/ 

Post: Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

You may prefer to, and are entitled to, lodge a complaint with a different supervisory authority in a country of your choice. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm 

DATA PROTECTION FOR CALIFORNIA CONSUMERS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

If you are a visitor, user, or other individual who resides in the State of California (“consumer”), you have the right to: (a) request that STARLIMS disclose what personal information it collects, uses, discloses and sells about you, (b) request deletion of the personal information you have provided to STARLIMS, and (c) be free from discrimination by STARLIMS as a result of you exercising your rights under the California Consumer Privacy Act of 2018 (“CCPA”).

We note that the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication from some of its requirements, such that the rights to access and delete your personal information do not apply with respect to such information.

In addition, under the CCPA, none of the rights set forth in this Notice apply to, and “personal information” does not include, certain categories of information, such as (i) publicly available information from government records, (ii) deidentified or aggregated consumer information, (iii) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, and (iv) information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

If you wish to exercise any of these rights, you must email [email protected]. Furthermore, in accordance with the CCPA, you can designate a third party agent to exercise your CCPA rights on your behalf.

California Consumers’ Right To Know

If you are a consumer, you have the right to request the following information regarding STARLIMS’ practices regarding your personal information: (a) the categories of personal information we have collected about you; (b) the categories of sources from which the personal information about you was collected; (c) the business or commercial purpose for which we collect or sell your personal information; (d) the categories of third parties with whom we share your personal information; (e) the specific pieces of personal information we have collected about you; (f) the categories of personal information that we sold about you, and categories of third parties to whom the information was sold; and (g) the categories of personal information that we disclosed about you for a business or commercial purpose.

California Consumers’ Right To Request Deletion

If you are a consumer, you have the right to request that STARLIMS delete the personal information that STARLIMS has collected about you that you provided to STARLIMS.  Please note that in certain instances we may not be able to process your request, such as (i) due to the existence of a legal obligation, (ii) to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, or (iii) in order to complete a transaction for which your personal information was collected.

California Consumers’ Right To Opt Out

STARLIMS has not sold the personal information of any California consumer to third parties in the preceding 12 months.  STARLIMS does not sell the personal information of minors under 16 years of age without affirmative authorization.

How can I contact STARLIMS?

If you have questions about your information, please contact us by clicking on the “Contact Us” link on the website you are visiting or by e-mailing us at  [email protected]. Alternatively, you may send a letter to the following address

 STARLIMS 

Attention: Public Affairs

4000 Hollywood Blvd, Suite 333 South 

Hollywood, FL 33021 – USA                              

In all communications to STARLIMS, please include the email address used for registration (if Applicable), the website address or the specific STARLIMS program to which you provided personal information (e.g. Starlims.com) and a detailed explanation of your request. We will do our best to respond to all reasonable requests in a timely manner.

How will I know whether STARLIMS has updated this policy? 

STARLIMS reserves the right to amend this Privacy Policy at any time. If STARLIMS changes its privacy practices, a new Privacy Policy will reflect those changes and the effective date of the revised Privacy Policy will be set forth in this paragraph. This Privacy Policy was last updated as of August 17, 2021 and is effective as of such date.