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Privacy Policy

We are delighted that you are visiting our website. The protection and security of your personal information when using our website is very important to us. We would therefore like to take this opportunity to inform you about which of your personal data we collect when you visit our website and for what purposes this data is used.

This privacy policy applies to the website of W. Soehngen GmbH, which is accessible via the domain www.aluderm.de and its various subdomains (‘our website’).

Who is responsible and how can I contact them
 

Data Controller
for the processing of personal data within the meaning of the EU General Data Protection Regulation (GDPR)

W. Söhngen GmbH
Platter Strasse 84
65232 Taunusstein
Germany

Managing Director(s) responsible: Andreas Harms

+49 (0)6128 873 0
info@soehngen.com

Data Protection Officer

Mr Sören Brunet

by email at datenschutz@soehngen.com

Postal address of the Data Protection Officer:

Sören Brunet
c/o MB ManagementBeratung, Lessingstraße 21, 26149 Wilhelmshaven

What is this about?

 

This privacy policy meets the legal requirements for transparency regarding the processing of personal data. This refers to any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, email address, IP address or your browsing behaviour when visiting a website. Information for which we cannot establish a link to your person (or can only do so with disproportionate effort), e.g. through anonymisation, does not constitute personal data. The processing of personal data (e.g. collection, retrieval, use, storage or transmission) always requires a legal basis and a defined purpose.

Stored personal data is deleted as soon as the purpose of the processing has been achieved and there are no legitimate grounds for further retention of the data. We will inform you of the specific retention periods or criteria for storage in the individual processing operations. Irrespective of this, we may store your personal data in individual cases for the purpose of asserting, exercising or defending legal claims, and where statutory retention obligations apply.

Who receives my data?

We only disclose your personal data, which we process on our website, to third parties if this is necessary to fulfil the purposes for which it was collected and is covered by the relevant legal basis (e.g. consent or the protection of legitimate interests) in each individual case. Furthermore, we may disclose personal data to third parties in individual cases where this serves to assert, exercise or defend legal claims. Potential recipients may then include, for example, law enforcement agencies, solicitors, auditors, courts, etc.

Where we use service providers for the operation of our website who process personal data on our behalf as part of a data processing arrangement in accordance with Article 28 of the GDPR, these may be recipients of your personal data. Further information on the use of data processors and web services can be found in the overview of the individual processing operations.

Do you use cookies?

Cookies are small text files that we send to the browser on your device and which are stored there when you visit our website. As an alternative to using cookies, information may also be stored in your browser’s local storage. Some functions of our website cannot be provided without the use of cookies or local storage (technically necessary cookies). Other cookies, however, enable us to carry out various analyses, so that we are able, for example, to recognise the browser you are using when you visit our website again and to transmit various pieces of information to us (non-essential cookies). With the help of cookies, we can, amongst other things, make our website more user-friendly and effective for you by, for example, tracking your use of our website and determining your preferred settings (e.g. country and language settings). Where third parties process information via cookies, they collect this information directly via your browser. Cookies do not cause any damage to your device. They cannot execute programs and do not contain viruses.

We provide information about the specific services for which we use cookies in the individual processing operations. You can find detailed information on the cookies used in the cookie settings or in the Consent Manager on this website

What rights do I have?

 

  • Access, in accordance with Article 15 of the GDPR, to the personal data stored about you in the form of meaningful information regarding the details of the processing, as well as a copy of your data
  • Rectification, in accordance with Article 16 of the GDPR, of inaccurate or incomplete data stored by us
  • Erasure pursuant to Article 17 of the GDPR of the data stored by us, provided that the processing is not necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise or defence of legal claims
  • Restriction of processing in accordance with Article 18 of the GDPR, provided that the accuracy of the data is contested, the processing is unlawful, we no longer require the data and you object to its erasure because you require it for the establishment, exercise or defence of legal claims, or you have objected to the processing in accordance with Article 21 of the GDPR
  • Data portability in accordance with Article 20 of the GDPR, provided that you have supplied us with personal data on the basis of consent pursuant to Article 6(1)(a) of the GDPR or on the basis of a contract pursuant to Article 6(1)(b) of the GDPR, and that this data has been processed by us using automated means. You will receive your data in a structured, commonly used and machine-readable format, or we will transmit the data directly to another controller, provided this is technically feasible
  • Objection pursuant to Article 21 of the GDPR to the processing of your personal data, insofar as this is carried out on the basis of Article 6(1)(e) or (f) of the GDPR and there are grounds for this arising from your particular situation, or the objection is directed against direct marketing. The right to object does not apply if compelling legitimate grounds for the processing are demonstrated or if the processing is necessary for the establishment, exercise or defence of legal claims. Where the right to object does not apply to specific processing operations, this is indicated there
  • Withdrawal pursuant to Article 7(3) of the GDPR of the consent you have given, with effect for the future
  • You may lodge a complaint with a supervisory authority in accordance with Article 77 of the GDPR if you believe that the processing of your personal data infringes the GDPR. As a general rule, you may contact the supervisory authority for your usual place of residence, your place of work or our registered office.


How exactly is my data processed?

Below, we provide information on the individual processing operations, the scope and purpose of data processing, the legal basis, the obligation to provide your data and the respective retention period. No automated decision-making, including profiling, takes place in individual cases.

Provision of the website

Nature and scope of processing

When you access and use our website, we collect the personal data that your browser automatically transmits to our server. The following information is temporarily stored in a log file:

  • IP address of the requesting computer
  • Date and time of access
  • Name and URL of the file accessed
  • Website from which access is made (referrer URL)
  • Browser used and, where applicable, your computer’s operating system, as well as the name of your internet service provided

Our website is not hosted by us, but by Amazon Web Services, Inc., based in Ireland (eu-west-1) (https://aws.amazon.com/de/), which processes the aforementioned data on our behalf in accordance with Article 28 of the GDPR.

Purpose and legal basis

The processing is carried out to safeguard our overriding legitimate interest in displaying our website and ensuring its security and stability, on the basis of Article 6(1)(f) of the GDPR. The collection of data and its storage in log files is essential for the operation of the website. There is no right to object to the processing due to the exception under Article 21(1) of the GDPR. Insofar as the continued storage of log files is required by law, the processing is carried out on the basis of Article 6(1)(c) of the GDPR. There is no legal or contractual obligation to provide the data; however, accessing our website is technically impossible without providing the data.

Retention period

The aforementioned data is stored for the duration of the website visit and, for technical reasons, for a maximum of 14 months thereafter.


Contact form

Nature and scope of processing

On our website, we offer you the option of contacting us via a form provided. The information collected via mandatory fields is necessary to process your enquiry. In addition, you may voluntarily provide further information which you consider necessary for the processing of your contact enquiry.

When using the contact form, your personal data will not be passed on to third parties.


Purpose and legal basis

The processing of your data when you use our contact form is carried out for the purpose of communicating with you and handling your enquiry on the basis of your consent in accordance with Article 6(1)(a) of the GDPR. Where your enquiry relates to an existing contractual relationship with us, the processing is carried out for the purpose of fulfilling the contract on the basis of Article 6(1)(b) of the GDPR. There is no legal or contractual obligation to provide your data; however, it is not possible to process your enquiry without the information in the mandatory fields. If you do not wish to provide this data, please contact us by other means.

Retention period

Where you use the contact form on the basis of your consent, we will store the data collected from each enquiry for a period of one year, starting from the resolution of your enquiry or until you withdraw your consent.


Contact form for applicants

Nature and scope of processing

We collect and process the personal data of applicants. Such data processing may also take place electronically, for example, when applicants submit application documents to us by email or via a web form on our website. On our website, we offer you the option of submitting applications for advertised vacancies to us by email.

Your data will only be stored in an applicant database beyond the current application process if you have given us your separate consent to do so.

Purpose and legal basis

The processing of your data in connection with your application is carried out for the purpose of processing your application and deciding on the establishment of an employment relationship on the basis of Section 26 of the German Federal Data Protection Act (BDSG). In the event that your application documents are passed on to third parties, in particular to companies affiliated with us, and your data is stored beyond the current application process, the processing of your data is carried out on the basis of Article 6(1)(a) of the GDPR. There is no legal or contractual obligation to provide your data; however, it is not possible to process your application without the provision of this information.

Retention period

We store the data collected for a period of 6 months from the date the position is filled.

 

Newsletter

Nature and scope of processing

If you sign up to receive our newsletter on our website, we collect your email address and, optionally, your customer number and business unit, and store this information together with the date of registration and your IP address. You will then receive an email in which you must confirm your subscription to the newsletter (double opt-in). If you do not confirm your subscription within 7 days, it will automatically lapse and the data will not be processed for the purpose of sending the newsletter.

We use a service provided by Sendinblue GmbH to send out the newsletter; they process your personal data on our behalf in accordance with Article 28 of the GDPR. Your data will not be passed on to third parties.

Purpose and legal basis

We process your data for the purpose of sending out the newsletter on the basis of your consent in accordance with Article 6(1)(a) of the GDPR. By unsubscribing from the newsletter, you may at any time withdraw your consent with future effect in accordance with Article 7(3) of the GDPR. There is no legal or contractual obligation to provide your data; however, it is not possible to send the newsletter without your data.

Retention period

Once you have subscribed to the newsletter, we store your data for a maximum of 7 days until your subscription is confirmed. Following successful confirmation, we store your data until you withdraw your consent (unsubscribe from the newsletter) and, for technical reasons, for a further maximum of 7 days.


Presence on social media platforms

We maintain so-called fan pages, accounts or channels on the networks listed below in order to provide you with information and offers within social networks and to offer you further ways to contact us and find out about our services. Below, we inform you about which data we or the respective social network process in connection with your access to and use of our fan pages/accounts.


Data we process about you

If you wish to contact us via Messenger or direct message on the relevant social network, we will generally process the username you use to contact us and may store any further data you provide, insofar as this is necessary to handle or respond to your enquiry.

The legal basis is Article 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the controller).

(Statistical) usage data we receive from social media platforms

We receive statistics regarding our accounts that are automatically provided via Insights features. The statistics include, amongst other things, the total number of page views, ‘Likes’, details of page activity and post interactions, reach, video views, and information on the proportion of men and women amongst our fans and followers.


The statistics contain only aggregated data that cannot be traced back to individual persons. We are unable to identify you from this information.

What data the social networks process about you

You do not need to be a member of the relevant social network to view the content of our fan pages or accounts, and no user account for that social network is required for this purpose.

Please note, however, that when you visit the respective social network, it collects and stores data even from website visitors without a user account (e.g. technical data required to display the website to you) and uses cookies and similar technologies, over which we have no control. Further details can be found in the privacy policies of the respective social network (see the relevant links above)

If you wish to interact with the content on our fan pages or accounts – for example, by commenting on, sharing or liking our posts – and/or contact us via messaging functions, you will need to register with the relevant social network in advance and provide your personal data.

We have no control over how social media platforms process your data when you use their services. To the best of our knowledge, your data is stored and processed in particular in connection with the provision of the respective social network’s services, and furthermore for the analysis of usage behaviour (using cookies, pixels/web beacons and similar technologies), on the basis of which advertising tailored to your interests is displayed both within and outside the respective social network. It cannot be ruled out that your data may also be stored by the social networks outside the EU/EEA and passed on to third parties.

Information regarding, amongst other things, the exact scope and purposes of the processing of your personal data, the retention period/deletion, as well as guidelines on the use of cookies and similar technologies in connection with registration and use of social networks, can be found in the privacy policies/cookie policies of the social networks. There you will also find information about your rights and options for objecting.

Instagram page

When you visit our Instagram page, Instagram (Meta) collects, amongst other things, your IP address and other information stored on your computer in the form of cookies. This information is used to provide us, as the operator of the Instagram pages, with statistical information regarding the use of the Instagram page. Instagram provides further information on this at the following link (Note: by clicking on the link below, you will be redirected to the website of the social network Facebook, which is also part of the Meta Group. However, the information provided via the link applies equally to the social network Instagram): www.facebook.com/help/pages.

The statistical information provided does not allow us to identify individual users. We use this information solely to cater to our users’ interests, to continuously improve our online presence, and to ensure its quality.

We collect your data via our fan page solely to enable communication and interaction with us. This collection generally includes your name, message content, comment content and the profile information you have made ‘public’.

The processing of your personal data for the purposes mentioned above is based on our legitimate business and communication interests in providing an information and communication channel in accordance with Article 6(1)(f) of the GDPR. Should you, as a user, have given your consent to data processing to the respective social network provider, the legal basis for the processing extends to Article 6(1)(a) and Article 7 of the GDPR.

As the actual data processing is carried out by the social network provider, our ability to access your data is limited. Only the social network provider is authorised to access your data in full. Consequently, only the provider can directly take and implement the necessary measures to fulfil your user rights (requests for information, requests for erasure, objections, etc.). It is therefore most effective to exercise such rights directly with the relevant provider.

We share responsibility with Instagram for the personal data contained on the fan page. Data subjects may exercise their rights by contacting Meta Platforms Ireland Ltd. or us.

Under the GDPR, the primary responsibility for the processing of Insights data lies with Instagram, and Instagram fulfils all obligations under the GDPR with regard to the processing of Insights data; Meta Platforms Ireland Ltd. makes the key elements of the Page Insights Supplement available to data subjects.

We do not make any decisions regarding the processing of Insights data or the retention period of cookies on users’ devices.

Further information can be found directly on Instagram (Supplemental Agreement with Facebook): www.facebook.com/legal/terms/page_controller_addendum.

Further information, including details on the exact scope and purposes of the processing of your personal data, the storage period/deletion, and guidelines on the use of cookies and similar technologies in connection with registration and use, can be found in Instagram’s Privacy Policy/Cookie Policy (Note: clicking on the link below will take you to the Facebook social network website):
privacycenter.instagram.com/policy/
This information can also be viewed in the help section of the Instagram website via the following link:
help.instagram.com/581066165581870

LinkedIn page

LinkedIn is a social network operated by LinkedIn Inc., headquartered in Sunnyvale, California, USA, which enables the creation of personal and professional profiles for individuals and company profiles. Users can maintain their existing contacts and make new ones within the social network. Companies and other organisations can create profiles to which photos and other company information can be uploaded, in order to present themselves as employers and recruit staff. Other LinkedIn users have access to this information and can write their own posts and share this content with others. The network focuses on professional exchanges on specialist topics with people who share the same career interests.

When using or visiting the network, LinkedIn automatically collects data from users or visitors during their visit, such as username, job title and IP address. This is done using various tracking technologies. LinkedIn provides users with information, offers and recommendations based, amongst other things, on the data collected in this way.

We collect your data via our company profile solely to enable communication and interaction with us. This collection generally includes your name, the content of your messages and comments, as well as the profile information you have made ‘public’.

The processing of your personal data for the purposes mentioned above is based on our legitimate business and communication interests in providing an information and communication channel in accordance with Article 6(1)(f) of the GDPR. Should you, as a user, have given your consent to data processing to the respective social network provider, the legal basis for the processing extends to Article 6(1)(a) and Article 7 of the GDPR.

As the actual data processing is carried out by the social network provider, our ability to access your data is limited. Only the social network provider is authorised to access your data in full. Consequently, only the provider can directly take and implement the necessary measures to fulfil your user rights (requests for information, requests for erasure, objections, etc.). The most effective way to exercise these rights is therefore to contact the relevant provider directly.

We are jointly responsible with LinkedIn for the personal data contained in our company profile. Data subjects may exercise their rights with LinkedIn Inc. or with us.

We do not make any decisions regarding the data collected on the LinkedIn website using tracking technologies.

For further information about LinkedIn, please visit: about.linkedin.com.

For further information on data protection at LinkedIn, please visit: www.linkedin.com/legal/privacy-policy.

Further information on retention periods/deletion, as well as guidelines on the use of cookies and similar technologies in connection with registration and use of LinkedIn, can be found at: de.linkedin.com/legal/cookie-policy.


Cookiebot

Nature and scope of processing

We have integrated Cookiebot into our website. Cookiebot is a consent solution provided by Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark, which enables consent to be obtained and documented for the storage of cookies. Cookiebot uses cookies or other web technologies to recognise users and to store the consent that has been given or withdrawn.


Purpose and legal basis
The service is used on the basis of obtaining the legally required consent to the use of cookies in accordance with Article 6(1)(c) of the GDPR.

Retention period
We have no influence over the specific retention period for the processed data; this is determined by Cybot A/S. Further information can be found in the Cookiebot privacy policy: www.cookiebot.com/de/privacy-policy/.

Cookiebot CDN

Nature and scope of processing

We use Cookiebot CDN to ensure the proper delivery of our website’s content. Cookiebot CDN is a service provided by Cybot A/S, which acts as a Content Delivery Network (CDN) on our website to ensure the functionality of other Cybot A/S services. You will find a separate section in this privacy policy regarding these services. This section deals solely with the use of the CDN.


Purpose and legal basis

The use of the Content Delivery Network is based on our legitimate interests, i.e. our interest in the secure and efficient provision and optimisation of our online offering in accordance with Article 6(1)(f) of the GDPR.

 

Retention period

We have no influence over the specific retention period of the processed data; this is determined by Cybot A/S. Further information can be found in the privacy policy for Cookiebot CDN: www.cookiebot.com/de/privacy-policy/.

Google Analytics

Nature and scope of processing

We use Google Analytics, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as an analytics service for the statistical evaluation of our website. This includes, for example, the number of visits to our website, the subpages visited and the length of time visitors spend on the site.

Google Analytics uses cookies and other browser technologies to analyse user behaviour and recognise users.

This information is used, amongst other things, to compile reports on website activity.

Purpose and legal basis

The use of Google Analytics is based on your consent in accordance with Article 6(1)(a) of the GDPR and Section 25(1) of the TTDSG.

We intend to transfer personal data to third countries outside the European Economic Area, in particular the USA. In cases where no adequacy decision has been issued by the European Commission (e.g. in the USA), we have agreed on other appropriate safeguards with the recipients of the data in accordance with Articles 44 et seq. of the GDPR. Unless otherwise stated, these are the EU Commission’s standard contractual clauses in accordance with Implementing Decision (EU) 2021/914 of 4 June 2021. You can view a copy of these standard contractual clauses at eur-lex.europa.eu/legal-content/DE/TXT/HTML/.

In addition, prior to such a transfer to a third country, we obtain your consent in accordance with Article 49(1)(a) of the GDPR, which you provide via the Consent Manager (or other forms, registrations, etc.). We would like to draw your attention to the fact that transfers to third countries may involve risks of which the details are unknown (e.g. data processing by the security authorities of the third country, the exact scope of which and the consequences for you we do not know, over which we have no influence and of which you may not become aware).

Retention period

We have no influence over the specific retention period of the processed data; this is determined by Google Ireland Limited. Further information can be found in the Google Analytics privacy policy: policies.google.com/privacy.

Google Tag Manager

Nature and scope of processing

We use Google Tag Manager provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Tag Manager is used to manage website tags via an interface and enables us to control the precise integration of services on our website.

This allows us to flexibly integrate additional services to analyse users’ access to our website.

Purpose and legal basis

The use of Google Tag Manager is based on your consent in accordance with Article 6(1)(a) of the GDPR and Section 25(1) of the TTDSG.

Retention period

We have no influence over the specific retention period of the processed data; this is determined by Google Ireland Limited. Further information can be found in the privacy policy for Google Tag Manager: marketingplatform.google.com/about/analytics/tag-manager/use-policy/.


Sendinblue

Nature and scope of processing

We have integrated components of the Sendinblue service into our website. Sendinblue is a service provided by Sendinblue GmbH and offers marketing automation for businesses.

Sendinblue is used to store and transmit data entered into forms via cookies, to send marketing emails and automated messages, and to create targeted campaigns.

In addition, Sendinblue enables us to analyse whether the emails sent have been opened, how many users have received an email, and whether users have unsubscribed from the newsletter after receiving an email.

In this case, your data is transferred to the operator of Sendinblue, Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin.

Purpose and legal basis

We process your data using Sendinblue for the purpose of optimising our website and for marketing purposes on the basis of your consent in accordance with Article 6(1)(a) of the GDPR.

Retention period

We have no influence over the specific retention period of the processed data; this is determined by Sendinblue GmbH. Further information can be found in Sendinblue’s privacy policy: www.brevo.com/de/legal/privacypolicy/.


YouTube NoCookie

Nature and scope of processing

We have integrated YouTube NoCookie into our website. YouTube NoCookie is a component of the video platform operated by YouTube, LLC, which allows users to upload content, share it online and receive detailed statistics.

YouTube NoCookie enables us to integrate content from the platform into our website.

YouTube NoCookie uses cookies and other browser technologies to analyse user behaviour, recognise users and create user profiles. This information is used, amongst other things, to analyse the activity of the content accessed and to generate reports. If a user is registered with YouTube, LLC, YouTube NoCookie can associate the videos played with the user’s profile.

When you access this content, you establish a connection to servers belonging to YouTube, LLC, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, whereby your IP address and, where applicable, browser data such as your user agent are transmitted.

Purpose and legal basis

Use of the service is based on your consent in accordance with Article 6(1)(a) of the GDPR and Section 25(1) of the TTDSG.

We intend to transfer personal data to third countries outside the European Economic Area, in particular the USA. In cases where no adequacy decision has been issued by the European Commission (e.g. in the USA), we have agreed on other appropriate safeguards with the recipients of the data in accordance with Articles 44 et seq. of the GDPR. Unless otherwise stated, these are the EU Commission’s standard contractual clauses in accordance with Implementing Decision (EU) 2021/914 of 4 June 2021. You can view a copy of these standard contractual clauses at eur-lex.europa.eu/legal-content/DE/TXT/HTML/.

In addition, prior to such a transfer to a third country, we obtain your consent in accordance with Article 49(1)(a) of the GDPR, which you provide via the Consent Manager (or other forms, registrations, etc.). We would like to draw your attention to the fact that transfers to third countries may involve risks of which the details are unknown (e.g. data processing by the security authorities of the third country, the exact scope of which and the consequences for you we do not know, over which we have no influence and of which you may not become aware).

Retention period

We have no influence over the specific retention period of the processed data; this is determined by YouTube, LLC. Further information can be found in the privacy policy for YouTube NoCookie: policies.google.com/privacy.

 

YouTube Video

Nature and scope of processing

We have integrated YouTube Video into our website. YouTube Video is a component of the video platform operated by YouTube, LLC, which allows users to upload content, share it via the internet and receive detailed statistics.

YouTube Video enables us to integrate content from the platform into our website.

YouTube Video uses cookies and other browser technologies to analyse user behaviour, recognise users and create user profiles. This information is used, amongst other things, to analyse the activity of the content viewed and to generate reports. If a user is registered with YouTube, LLC, YouTube Video can associate the videos played with their profile.

When you access this content, you establish a connection to the servers of YouTube, LLC, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, whereby your IP address and, where applicable, browser data such as your user agent are transmitted.

Purpose and legal basis

Use of the service is based on your consent in accordance with Article 6(1)(a) of the GDPR and Section 25(1) of the TTDSG.

We intend to transfer personal data to third countries outside the European Economic Area, in particular the USA. In cases where no adequacy decision has been issued by the European Commission (e.g. in the USA), we have agreed on other appropriate safeguards with the recipients of the data in accordance with Articles 44 et seq. of the GDPR. Unless otherwise stated, these are the EU Commission’s standard contractual clauses in accordance with Implementing Decision (EU) 2021/914 of 4 June 2021. You can view a copy of these standard contractual clauses at eur-lex.europa.eu/legal-content/DE/TXT/HTML/.

In addition, prior to such a transfer to a third country, we obtain your consent in accordance with Article 49(1)(a) of the GDPR, which you provide via the Consent Manager (or other forms, registrations, etc.). We would like to draw your attention to the fact that transfers to third countries may involve risks of which the details are unknown (e.g. data processing by the security authorities of the third country, the exact scope of which and the consequences for you we do not know, over which we have no influence and of which you may not become aware).

Retention period
We have no control over the specific retention period for the processed data; this is determined by YouTube, LLC. For further information, please refer to YouTube’s privacy policy: policies.google.com/privacy.