MENU WEX EUROPE » PRIVACY POLICY Privacy Policy Overview WEX Europe is part of a group of companies who may process personal data of individuals. This group includes the companies set out below. WEX is committed to protecting the personal data and privacy of individuals when providing its websites, apps, platforms and services (“Services“). This Privacy Policy explains how we do this and how and why we collect and use any personal data that is provided to us, or which we collect in the provision and use of our Services. It describes: The information identifying individuals that we collect. How we use this personal data. The legal basis upon which we process it. With whom it is shared. How it is stored. This Privacy Policy also describes other important topics relating to personal data and privacy compliance, including how we use cookies on our websites, and sets out various rights that individuals may exercise in respect of our use of their personal data as set out in section 12 below. Two fundamental rights are that individuals may: Ask us to stop using their personal data for direct-marketing purposes. If an individual exercises this right, we will stop using their personal data for this purpose. Ask us to consider any valid objections which an individual has to our use of their personal data where we process their personal data on the basis of our, or another person’s, legitimate interest. This Privacy Policy applies to personal data we collect through those of our websites and apps on which it is displayed (including any client login areas of those websites), or which is provided to us by email or telephone, or which we collect from third parties. Please read this Privacy Policy carefully to understand how we handle personal data of individuals. Policy in detail This Privacy Policy is comprised of the following section: Index 1. Information about the WEX Group 2. WEX Group reorganisation 3. Corporate use of our Services 4. Application of this Privacy Policy 5. Services covered by this Privacy Policy 6. Data Collected 7. Data Usage 8. Legal basis for use of your personal data 9. Cookies 10. Disclosure of your personal data 11. Retention of your personal data 12. Your rights 13. Marketing 14. Data transfers 15. Account Security 16. Website Security 17. Our security practices 18. Third Party Websites 19. Phishing emails 20. Changes to our Privacy Policy 21. Further questions or making a complaint 1. Information about the WEX Group Certain WEX group companies collect, process, transfer and store personal data in accordance with this Privacy Policy. The relevant WEX company involved will depend on the Services, but include the following: WEX Europe Limited (Company number 05927983), a company organised and existing under the laws of England, registered at 4th Floor, East Building, 1 London Bridge, London, SE1 9BG, United Kingdom WEX Europe UK Limited (Company number 10485907 and FCA reference number 900747), an authorised electronic money issuer, registered at 4th Floor, East Building, 1 London Bridge, London, SE1 9BG, United Kingdom In this Privacy Policy, when we refer to “WEX“, “us“, “we” or “our“, we mean the relevant WEX group company or companies which provides the relevant Service. 2. WEX Group reorganisation Please note that following an internal re-organisation, as of 30 October 2017 certain Services previously provided by WEX Europe Limited are now provided by WEX Europe UK Limited, and various contractual arrangements with WEX Europe Limited and other third parties have been transferred to WEX Europe UK Limited. Accordingly, WEX Europe UK Limited is now a data controller over any personal data collected pursuant to the Services it now provides and will continue to collect and process such personal data in accordance with this Privacy Policy. WEX previously used R. Raphael & Sons plc (“Raphaels“) to provide certain e-payment solution services in relation to certain Services. Following the re-organisation referenced above, these services are now provided by WEX Europe UK Limited, and various contractual arrangements with Raphael’s have been transferred to WEX Europe UK Limited. Accordingly, WEX Europe UK Limited is now a data controller over any personal data collected pursuant to the services previously provided by Raphaels and the Services it now provides, and will continue to collect and process such personal data in accordance with this Privacy Policy. 3. Corporate use of our Services Other than the general use of the WEX websites, the Services are provided by WEX to its corporate customers on a business to business basis. As part of the Services WEX may collect certain personal data about individuals, such as when individuals register for, access, and use the Services on behalf of such corporate customer. This may include information that relates to the customer or information relating to the individual in its capacity as an employee or agent of such customer (and not in a personal or private or consumer context). To the extent WEX does collect and use personal data as a data controller as part of the Services, it does so in accordance with this Privacy Policy. In relation to an individual’s use and our provision of the Services, this is governed by our agreement with our customer which sets out the terms on which we provide the Services and our rights, obligations and protections in relation to the Services. Our liability in relation to the Services is subject to the terms of this agreement with our customer. Any questions in relation to the Services or our agreement with the customer, should be raised with the relevant employer entity (or the party that instructs the individual to use the Services). 4. Application of this Privacy Policy This Privacy Policy applies only where we act as a data controller over the personal data of our customers, personnel that work for our customers, website visitors, our suppliers (and potential suppliers), and personnel of such suppliers and contractors. When you give us personal data about another person, you confirm that they have appointed you to act for them and that they are aware of how we may use their personal data as set out in this Privacy Policy. 5. Services covered by this Privacy Policy The Services covered by this Privacy Policy include those provided on www.wexeurope.com, the WEX Prepaid Card Services Portal (also known as PLog, www.prepaycardservices.com), and any other websites, apps, online portals and services that provide a link to (or other reference to) this Privacy Policy. When visiting pages hosted on other third-party websites, or using services provided by third parties, individuals should refer to their privacy policies and terms of use for more information about how they handle your information. 6. Data Collected We may receive some information directly from the individual (such as when an individual registers as a user of our Services). However, we may also receive data about an individual from third parties such as the individual’s employer, our suppliers, marketing partners, social media providers, issuing firms, third party integrators and payment institutions, merchants, our group companies and public websites, which we refer to as “Third Party Sources” throughout this Privacy Policy. In this Privacy Policy “personal data” means information from which an individual can be personally identified, including for example, an individual’s name, email address, postal address, phone number, and payment card information. We may combine the personal data we receive from an individual with information we receive about the individual from Third Party Sources. Personal data does not include data collected as part of the Services from which we cannot identify an individual, or information which would not enable us to identify an individual (such as by removing certain information which would mean that we are not enable to identify an individual personally). We and our service providers may collect non-personal data that does not reveal an individual’s specific identity or does not directly relate to an individual. Because this information does not personally identify an individual, we may use and disclose it for lawful purposes. If we are required to treat such data as personal data under applicable law, then we may use and disclose it for the purposes for which we use and disclose personal data under this Privacy Policy. We may combine the non-personal data we collect from and about an individual with personal data, but if we do, we will treat the combined information as personal data for as long as it is combined. Read below to find out more about the personal data that we, or third parties on our behalf, may collect and use. Personal data which you (or a third Party Source) give us Individual’s may give us personal data about themselves using the online forms provided on our websites, providing information during events such as business cards, completing order forms, setting up an account with us, or by contacting us by phone, e-mail or other means. Third Party Sources may also give us personal data about individuals when we work with them in relation to the provision of our Services. We also collect personal data when our corporate customer provides us with individual registration details to enable us to provide the Services (even if you do not actually submit your request or registration). When a customer applies for Services from us (or from one of our partners) they will be asked to provide personal data of relevant individuals so that we can register them to use the Services. We also work closely with third parties (including, for example, business partners, card issuers and sponsors, sub-contractors in technical, payment and delivery services, analytics providers, credit reference agencies) and we may receive personal data about individual’s from these Third Party Sources in order to provide and manage the Services and our business operations. This personal data will include: Data about the individual: name job title / occupation company name e-mail address phone number company’s address date of birth drivers licence number political party (as required for any compliance checks) data provided when the individual correspond with us any updates to data provided to us Data related to the services we provide to the individual or their employer: data needed to provide our Services (including data on account opening forms, details of transactions, transaction history, payment details, trade references and tax information) bank account number, billing / account information, and credit/ debit card number customer services data customer relationship management marketing data Please note that we need certain types of this personal data so that we can provide our Services or so our third parties can provide services to us. If we aren’t provided with such personal data, or if an individual asks us to delete it, they may no longer be able to access our Services or provide goods and/or services to us. Personal data we collect about you (including from Third Party Sources) Each time an individual visits our websites we may automatically collect any of the following data: data about the visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), time and length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), the internet service providers (ISP), referring/exit pages, operating systems used, date/time stamps, and click stream data, methods used to browse away from the page, traffic data, location data, weblogs and other communication data and data provided when requesting further service or downloads. technical data, including the Internet protocol (IP) address used to connect the individual’s computer to the internet, domain name and country which requests data, mobile device serial numbers, the files requested, browser type and version, browser plug-in types and versions, operating system and platform. To make sure we follow any instructions correctly and to improve the Services through training of our staff, we may also monitor or record telephone calls. If the individual is a customer or a supplier (or a potential customer or supplier) or works for one of them (including as a consultant), we may obtain data about them from the relevant company’s website. We also collect anonymised details about visitors to our websites for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes. 7. Data Usage The personal data that an individual provides to us will only be used for the purposes described at the time of their application, as outlined in the terms and conditions that apply to the relevant Service and as set out in this Privacy Policy. These uses include the following categories of usage: Providing our Services to register individuals as a user of our Services and to manage the individual’s or their employer’s account, including: providing the information and services the individual or their employer have requested, and to provide customer services, technical support and account maintenance inform the individual of any changes made to the Services or send them other administrative information for assessment and analysis including identity verification, behaviour scoring, and market and product analysis develop and improve our products and services to ensure the security of our services and our websites to store information about the individual’s preferences to provide relevant Services to the individual or their employer (including, to confirm and process orders, for administration of accounts with us, tax, invoicing and debt collection purposes). to deal with any enquiries or issues about our Services, including any questions an individual may have about how we collect, store and use their personal data, or any requests made by the individual for a copy of the data we hold about them. If we do not have a contract with the individual, we may process the personal data for these purposes where it is in our legitimate interests for customer services purposes. to send certain communications (including by email or post) about our Services such as service announcements and administrative messages (for example, setting out changes to our terms and conditions and keeping individuals informed about our fees and charges). for legitimate business development and marketing purposes, to contact individuals (including by email or post) with information about our Services which either the individual requests, or which we feel will be of interest to them. To provide interest-based advertising on our websites using information the individual makes available to us when they interact with our Services. For profiling and statistical analysis. As part of this activity we combine different categories of personal data that we collect about individuals. For example, we combine personal data from online interactions and information shared with us to build a marketing profile so that we are able to send marketing communications to individuals that we believe are most relevant to them (such as based on their job description, location and any of your stated preferences). Individuals have the right to object to the processing of personal data in this way. For more information on how to exercise the right to object, see section 12 below. For internal corporate reporting, audits, business administration, ensuring adequate insurance coverage for our business, and to identify and implement business efficiencies. To comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so. To establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so. As part of our checks to prevent fraud and money laundering, personal data that is provided to us may be disclosed to a credit reference or fraud prevention agency, who may keep a record of that information. These checks are performed to confirm an individual’s identity only and a credit check is not performed and an individual’s credit rating will be unaffected. If an individuals does not complete a registration process we may use any personal data that they have already provided to us to contact them to make sure that they do not wish to proceed with registration. We will not use an individual’s personal data in any way that is incompatible with the purposes set out in this section 7 without contacting the relevant individual first. Individuals should contact us at the details set out at the end of this policy if they want further information on the analysis we will undertake to establish if a new use of their personal data is compatible with these purposes. 8. Legal basis for use of your personal data We consider that the legal bases for using an individual’s personal data as set out in this Privacy Policy are as follows: Our use of the personal data is necessary to perform our obligations under any contract with the individual (for example, to comply with the terms of use of our websites which the individual accepts by browsing our websites). Our use of the personal data is necessary for complying with our legal obligations (for example, providing information to HMRC, conduct anti money laundering (AML) and politically exposed person (PEP) checks). The individual consents, where set out in this Privacy Policy, or where we otherwise specifically seek this from the individual. More information on consent In the future, certain new uses of personal data may require us to obtain consent from the individual. In those cases, that need for consent will be identified in this Privacy Policy and/or at the time we collect the personal data. Where we rely on consent for us to use your personal data in a particular way, but the individual later changes their mind, the individual may withdraw their consent by contacting us at the details set out at the end of this Privacy Policy or, in relation to marketing, by unsubscribing from the marketing communications using the link in the communications, and we will stop doing so. However, if the individual withdraws their consent, this may impact the ability for us to provide our Services. Where none of the grounds above apply, where use of the personal data is necessary for our legitimate interests or the legitimate interests of others (for example, to provide our Services to our customers, or to ensure the security of our Services). In some cases, we have identified where this is the case elsewhere in this Privacy Policy. Our legitimate interests are to: run, grow and develop our business operate our websites select appropriately skilled and qualified suppliers undertake marketing, market research and business development provide Services to our customers, account management, to process transactions, and provide customer service support fraud prevention, regulatory compliance and risk management and risk reporting know our customers and any of their service users for internal group administrative purposes, as described in section 10 below. If we rely on our (or another person’s) legitimate interests for using your personal data, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal data. An individual can ask us for information on this balancing test by contacting us at the details set out at the end of this Privacy Policy. 9. Cookies Our websites use cookies, which are small files placed on an individual’s device when they visit our websites. We use cookies to distinguish an individual from other users of our websites and to collect other information to help us to provide a better experience when individuals browse our websites and to allow us to monitor and improve our Services. Individuals may block the use of cookies at any time. To do so, an individual can activate the setting in their browser that allows them to refuse the setting of all or some cookies. However, if an individual uses their browser settings to block all cookies (including essential cookies), they may not be able to access all or parts of our Services or to use all the functionality provided through our Services. Our Cookie Policy below explains what cookies we use on our websites, what information we may use or store through our cookies and how cookies can be disabled. 10. Disclosure of your personal data We may share personal data, [including financial data] with any company that is a member of our group, which includes our group companies based in the US, where it is in our legitimate interests to do so for internal administrative purposes (for example, ensuring consistent and coherent delivery of services to our customers, corporate strategy, compliance, auditing and quality assurance). We may also share personal data with our group companies where they provide services to us, such as information technology systems, or where they are involved in the provision of our Services. We will share your personal data with the following categories of third parties: Our service providers and sub-contractors, including but not limited to CRM platform providers, payment processors, and suppliers of technical and support services. To persons acting as our agents (and our partners who sell and/or market our cards from time to time) and to partners with whom we run loyalty and/or currency card programmes. To our corporate customer (likely an individual’s employer or the organisation otherwise instructing them to use our Services), where the card has been provided for use in the course of your employment. Public agencies (including tax officials). Companies that assist us in our marketing, advertising and promotional activities (including but not limited to marketing by WEX group companies or partners whose brand is on the card). Analytics and search engine providers that assist us in the improvement and optimisation of our website. Any third parties with whom we share personal data are limited (by law and by contract) in their ability to use personal data for any purpose other than to provide services for us. We will always ensure that any third parties with whom we share personal data are subject to privacy and security obligations consistent with this privacy policy and applicable laws. Information on why we share your personal data We disclose personal data to third parties: Where it is in our legitimate interests to do so to run, grow and develop our business, such as: if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. if substantially all of our or any of its affiliates’ assets are acquired by a third party, in which case personal data held by WEX will be one of the transferred assets. If we are under a duty to disclose or share personal data in order to comply with any legal obligation (including laws outside an individual’s country of residence), any lawful request from government agencies (including public and government authorities outside an individual’s country of residence) or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity. In order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity. To protect the rights of WEX, our staff, our customers or other persons. This may include: exchanging personal data with other organisations (including fraud prevention agencies, regulatory bodies and other organisations) for the purposes of fraud protection and credit risk reduction and to prevent fraud and money laundering. for the purpose of enforcing contractual rights and obligations. to protect our rights, privacy, safety or property, and/or that of the WEX group of companies, you or others. Save as set out above, we will never share, sell or rent any of personal data to any third party without notifying the individual and, where necessary, obtaining their consent. If an individual has given their consent for us to use their personal data in a particular way, but later change their mind, they can contact us to withdraw their consent using the details set out at the end of this policy. 11. Retention of your personal data We keep personal data for no longer than necessary for the purposes for which the personal data is processed. The length of time for which we retain personal data depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. 12. Individuals’ rights Individuals have certain rights in relation to their personal data. If an individual would like further information in relation to these or would like to exercise any of them, they can contact us by email at the details set out at the end of this Privacy Policy. Subject to certain exemptions permitted by law, individuals have the following rights: Right of access. Individuals have a right of access to any personal data we hold about them. They can ask us for a copy of their personal data; confirmation whether their personal data is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer their personal data outside of the EEA. Right to update your information. Individuals have a right to request an update to any of their personal data which is out of date or incorrect. Right to delete your information. Individuals have a right to ask us to delete any personal data which we are holding about them in certain specific circumstances. Right to restrict use of your information: Individuals have a right to ask us to restrict the way that we process their personal data. Right to stop marketing: Individuals have a right to ask us to stop using their personal data for direct-marketing purposes. If they exercise this right, we will stop using their personal data for this purpose. Right to data portability: Where we use personal data on the basis of an individual’s consent or performance of a contract, they have a right to ask us to provide their personal data to a third party provider of services. Right to object. Individuals have a right to ask us to consider any valid objections which they have to our use of their personal data where we process their personal data on the basis of our or another person’s legitimate interest, or where we use their personal data for profiling purposes. We will consider all such requests and provide our response within a reasonable period (and in any event within one month of the request unless we are entitled to a longer period allowed by applicable law). Please note, however, that certain personal data may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. We may request that the individual provides us with information necessary to confirm their identity before responding to any request you make. If an exception applies we will inform the individual of this when responding to their request. If an individual wants to know more about these rights, when they might not apply or where they are subject to certain exceptions, they can contact us at the details set out at the end of this Privacy Policy. Alternatively, the Information Commissioner’s Office website sets out further information on individuals’ rights. 13. Marketing We may collect and use personal data for undertaking marketing by email, telephone and post. We may send certain marketing communications (including electronic marketing communications to existing customers) to individuals if it is in our legitimate interests to do so for marketing and business development purposes. If an individual wishes to stop receiving marketing communications, they can contact us at any time at the details set out below or by email at privacy@wexinc.com. They may also unsubscribe using the unsubscribe link in any electronic communication we send to them. They will however still receive operational and administrative messages related to the Service they use and any enhancements or changes to these Services. We may also use and disclose anonymous information (so that no individual is identified) for marketing and strategic development purposes. 14. Data transfers The personal data we hold about individuals may be used, stored and/or accessed outside the UK or EEA by staff working for us, other members of our group or third party partners providing services to us, or performing services on our behalf. This may be for the purposes listed in section 6 above, the provision of our Services, the processing of transactions and/or the provision of support services. Further details on to whom personal data may be disclosed are set out in section 10 above. By submitting personal data individuals acknowledge that it may be subject to such transfer, storage or processing outside of the UK and EEA. In particular, our data is hosted on group servers in the US and the EEA. Where we transfer personal data outside of the UK or EEA we will take appropriate measures to ensure that the recipient protects the personal data adequately in accordance with this Privacy Policy and we will ensure that such transfers comply with applicable data protection laws. These measures include, but are not limited to: In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further on the US Privacy Shield website). In the case of entities based in other countries outside the EEA, including US based entities that have not self-certified to the US Privacy Shield, entering into European Commission approved standard contractual arrangements with them. 15. Account Security We take the security of personal data very seriously. On registering an account with us, an individual will be provided with a username, password and/or passcode (“Access Credentials”) which must be used in order to access our Services including certain restricted parts of our websites. Access Credentials are used by us to identify individual users and so are very important. Individuals are responsible for all services accessed by anyone using their Access Credentials. As soon as they become aware of or suspect that someone else is using your Access Credentials they must notify us immediately at privacy@wexinc.com. Recommendations on what an individual should do to keep their account secure: Never reveal your passcode or password to anyone. Do not use a passcode or password that could be easily guessed by someone else. Change your passcode and password immediately if you suspect someone else could know it. Log off any website and close your web browser when you have completed your transaction. Keep your PC updated with current anti-virus software and the latest browser versions. Do not send us any confidential account information via email. Treat emails you receive with caution. Remember we will never ask you to disclose your personal or account information to us by email. In particular we will never ask you to disclose your card PIN to us. We recommend that individuals regularly visit the Financial Fraud Action website to keep up to date with tips to protect yourself from the latest scams. 16. Website Security Unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect personal data, we cannot guarantee the security of data transmitted to our online Services and any transmission is at the individual’s own risk. Once we have received any personal data, we will use strict procedures and security features to try to prevent unauthorised access. 17. Our security practices The main risk of our processing of personal data is if it is lost, stolen or misused. This could lead to an individual’s personal data being in the hands of someone else who may use it fraudulently or make public information that you would prefer to keep private. For this reason, WEX is committed to protecting personal data from loss, misuse, disclosure, alteration, unauthorised access, unavailability and destruction and takes all reasonable precautions to safeguard the confidentiality of personal data, including through use of appropriate organisational and technical measures. Organisational measures include physical access controls to our premises, implementing internal policies and staff training and ensuring confidentiality obligations are imposed on our employees and third parties. Technical measures include requiring passwords for access to our systems, the use of encryption and anti-virus software and logically separating data. Our systems operate using industry standard encryption. Encryption makes the personal data unreadable to anyone who might intercept it. 18. Third Party Websites Our Services may contain links to other websites which are not operated by WEX. Additionally, there may be unauthorised third party websites that may be providing links from their sites to our Services without our knowledge or control. This Privacy Policy does not apply to such linked or linking websites and we have no responsibility for the privacy standards, cookie usage, content or any goods or services that may be provided on those other websites. Individuals are solely responsible for ensuring that they familiarise themselves with the privacy policies and practices and any terms and conditions that may be applicable to their use of any such website and we encourage individuals to review the policies of all such sites carefully. 19. Phishing emails From time to time we may send emails relating to the payment card or individuals may also receive marketing emails from us. However our emails will never ask an individual to provide us with their log in details or passcode but we may direct you to our top up and/or login page – individuals should never enter your log in details on a website link which is emailed to them if they are not certain that the email is from us. If an individual has any doubts about an email they receive, then they should contact our customer services team using the contact details at the end of this Privacy Policy who will be able to assist. Emails which are not from us or the institution which issued the payment card may be “phishing” emails. Some helpful information on phishing and what to look out for can be found on the Action Fraud website as well as on the Financial Fraud Action website. 20. Changes to our Privacy Policy From time to time, we may make changes to the Privacy Policy. Such changes may be in relation to changes in the law, best practice or changes in our Services or business policies and/or processes. Any changes that we make will be updated on this Privacy Policy page and, if appropriate, we may draw attention to the changes by marking them on this page, by posting a notice of the changes on WEX Europe’s home page www.wexeurope.com, or by email or an in-service message. An individual can determine when this Privacy Policy was last revised by referring to the “last updated” legend at the bottom of this Privacy Policy. An individuals continued use of the Services following our making available any revised version of this Privacy Policy will mean that they have read and understood that revised version. 21. Further questions or making a complaint If an individual has any questions, comments or concerns about any aspect of this Privacy Policy, how WEX handles their personal data, or if they would like to exercise any of their rights in relation to their personal data they should contact us at the details below. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of their personal data as soon as possible. Our contact details are: By email: privacy@wexinc.com Online: through our Customer Services Team’s contact page By post: Data Protection, 4th Floor, East Building, 1 London Bridge, London, SE1 9BG, United Kingdom General information about data protection may be found on the UK Information Commissioner’s website. An individual may make a complaint to Information Commissioners’ Office in the UK or, in certain circumstances, the data protection authority in the European Union country where they usually live or work. Alternatively an individual may seek a remedy through local courts if they believe that their rights have been breached. Last updated This Privacy Policy was last updated on 14 June 2019. 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