Firefly — Online Privacy Statement

Welcome to www.fireflylockhart.com, our mobile applications (the “Sites”) and the online services of VMP Lockhart Properties, LLC (“we,” “our,” or “us”) provided through the Sites. This Online Privacy Statement (the “Privacy Statement”) explains how we collect, use, disclose, and protect the Personal Information that we collect through our Services, and your choices about the collection and use of such information.

Throughout this Privacy Statement, we collectively refer to the Sites and any services offered through them as the “Services.” When you use our Services, you agree that we may use and disclose your Personal Information as described in this Privacy Statement and you agree to comply with our Terms and Conditions available here: www.fireflylockhart.com/terms. If you do not consent to our Terms and Condition or this Privacy Statement, you should not use the Services or otherwise provide us with any Personal Information.

Please note that this Privacy Statement does not describe the practices of any other party that may have access to your Personal Information. To the extent that we provide your Personal Information to our agents or service providers, we will take what we believe to be commercially reasonable steps to ensure that they safeguard such information and use it only for the intended purposes. However, we are not responsible for the practices employed by any third-party website that we may link to, nor for the information or content contained therein. We encourage you to review the privacy statements of such other websites to understand their information practices and terms of service.

 

1. INFORMATION WE COLLECT

Capitalized terms that are not defined in this Privacy Statement have the meaning given to them in our Terms and Conditions. For purposes of this Privacy Statement, “Personal Information” means information that would allow someone to identify or contact you or your computing device.

We collect the following types of information about you from you or from third parties:

Registration Information. We may ask for certain types of Personal Information, such as your first and last name, phone number, current address, job title and company information, and e-mail address when you register on the Site to create an account.

Contact information: We may ask for certain contact information such as your name, phone number, address, and email address when you use the Site or otherwise correspond with us.

Financial Information: We also may ask whether you are interested in selling your current home, for a copy of your mortgage preapproval or other financial information, and for information about your relationship with your real estate agent.

News alerts or other publications: You may be able to use the Site to subscribe to our news, alerts, blog, or other publications. We will ask you to provide Personal Information such as your name, contact details and topics of interest. We will use this information to provide you with the content you have requested and to tailor this content to your preferences and areas of interest.

Aggregate or Demographic Information: We may collect and analyze aggregate data assembled from Personal Information collected via the Services. Aggregate data is collected in order to better understand the demographics and usage patterns of all users of the Services, so that we can provide the highest level of service to our customers. Such aggregate data generally is not personally identifiable or linked to a specific user.

We or third parties collect the following types of information automatically when you visit the Site:

Technical Information: Our servers may automatically collect certain technical information about your use of the Services, including, without limitation, your browser type, your operating system, Internet Protocol address, and bandwidth speed. We also may track your activity on our Site, including pages visited, buttons or links clicked, emails opened, etc. Some technical information may qualify as Personal Information, while other technical information may not be personally identifiable. We generally use technical information for system administration, security and statistical analysis.

Mobile Device Data: Certain mobile devices contain unique identifiers that can be used, for example, to identify the physical location of such devices. When you access the Services, or use the features provided in the Services, through a mobile device, we may collect, use, transmit, process and maintain unique identifiers, caller ID data, location-based data, and similar information for various purposes, including to provide the Services you request and to improve your experience with the Services. we may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

Cookies and similar technologies: We use cookies and similar technology to collect aggregate (non-personal) information about Site usage by all our visitors and to help us remember you, your account information, and your preferences when you revisit the Site. These cookies may stay on your browser into the future until they expire, or you delete them. We also use technology to remember your navigation through our Site. These cookies usually are erased when you close your browser window. Further general information about cookies and how they work is available at www.allaboutcookies.org.

We may allow selected third parties to place cookies through the Site to provide us with better insights into the use of the Site or user demographics or to provide relevant advertising to you. From time-to-time, we may engage third parties to track and analyze non-personally identifiable usage and volume statistical information from individuals who visit our Services. These third parties may collect information about a consumer’s online activities over time and across different websites when he or she uses our website. We may also permit third party service providers to place cookies through our Site to perform analytic or marketing functions where you 2 are notified of them, and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information and we are not responsible for any actions or policies of such third parties.

You also may see advertisements when you use our Site. These advertisements are for our own products or services or for products and services offered by third parties. Which advertisements you see is often determined using the information that we, our service providers, and other companies that we work with have about you, including information about your relationships with us. To that end, where permitted by applicable law, we may share with others the information that we collect from and about you.

 

2. HOW WE USE YOUR INFORMATION

We use the information we collect for our general commercial purposes such as to improve our Site, manage our staffing and human resources administration, grow our business and to respond to your inquiries or to provide information on products or services to you, including without limitation, to:

1. Operate, maintain, and provide to you the services and information you have requested from us and notices relating thereto including providing customer and technical support.
2. Create your account and verify that you qualify as a registered user of the Site if registration is required to access certain portions of the Site.
3. Provide information to you about our products or services and third-party products and services that we think may be of interest to you.
4. Communicate directly with you, such as to send you legally required disclosures, email messages, telephone calls, and/or text messages including Services-related emails or messages (e.g., account verification requests, order confirmations, offers and/or counteroffers, notifications of changes or updates to features of the Services, and technical and security notices). • Provide you with marketing communication and information.
5. Analyze, improve, and customize the Site including measuring the effectiveness of advertising and internal research on users’ interests and behaviors to better serve our users.
6. Administer the website, web platform and our services and for internal operations, including troubleshooting, data analysis, testing, research, security, statistical and survey purposes.
7. Respond to questions or requests or to contact you for lawful purposes, including for surveys;
8. Comply with legal or regulatory obligations and reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. To create de-identified, anonymized, aggregated or similar non-personally identifiable data, which we may use and share for any lawful business purpose;
9. Engage in routine business uses that an ordinary and reasonable person should expect in the context of the Services that we provide, the reasons for which we collect Personal Information, and/or the ways that similar businesses ordinarily operate, including, for example, uses and disclosures;
10. To conduct internal and external audit requirements, for information-security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions or other agreements; and (d) to protect our rights, privacy, safety, or property, or those of other persons.

 

3. SHARING OF YOUR PERSONAL INFORMATION

We may disclose your Personal Information to third parties in order to provide the Services and for other reasons. Such third parties may include affiliated or unaffiliated companies and other entities.

Subject to applicable law, the reasons that we may disclose your personal information include:

1. to service providers, information technology providers, consultants, mailing and other business process providers, vendors, and other third parties which help us to operate and improve our business, including by providing analytic services;
2. to service providers, vendors and other third parties whose goods and services we market on our site and to our residents so that such companies may offer you their products and services and so such companies may perform any services for which you have subscribed in accordance with their terms and conditions;
3. to other companies owned by us or under common ownership, including to our subsidiaries, or to our ultimate holding company and any of its subsidiaries. These companies may use your Personal Information in the same way as we can under this Privacy Statement;
4. for security, anti-fraud, authentication and verification purposes;
5. to vendors and their service providers who reasonably need the personal information to do their jobs, which may include helping us to analyze how the Services are used, diagnose service or technical problems, customize content or deliver personal communications, and/or protect the security or integrity of the Services;
6. to our co-branded business partners with whom we may jointly provide Services to you;
7. to respond to or participate in commercial disputes (e.g., lawsuits or investigations);
8. to persons appearing to have a lawful interest in the Personal Information (e.g., to an insurance company processing an insurance claim involving you); or
9. to comply with applicable law;
10. In connection with a merger or other business combination or separation (including, but not limited to, a voluntary or involuntary change in our business or structure, or a reorganization, financing, change of control, sale of all or part of our stock or assets, spinoff, bankruptcy, dissolution, or any related to similar proceedings);
11. To respond to legal process or to regulatory authorities (such as pursuant to a subpoena; warrant; investigative demand from law enforcement, regulators or others; national or international security letters; etc.)
12. To investigate, prevent, or take action regarding suspected or actual illegal activities (including fraud or stalking), security or technical issues;
13. To protect against fraud, claims, or other liability or harm to you, us, or others;
14. To exercise or perform a legal, ethical, contractual, or other right or obligation, such as to enforce our Terms and Conditions or other agreements, or to investigate potential violations thereof; and
15. For such lawful purposes as may be disclosed or evident at the time that you provide Personal Information to us (e.g., when you provide Personal Information in response to a survey, to sign up for an event, or to register for a newsletter).

We do not share mobile information outside of The Amherst Group of companies, our affiliates and their authorized service providers, and your mobile information is never shared with third parties (affiliated or not) for their marketing purposes.

For further information on your choices regarding your information, see the section below called, “Your Choices Regarding Your Information.”

 

4. HOW WE STORE AND PROTECT YOUR INFORMATION

Storage and Processing: Personal Information collected through the Services may be stored and processed in the United States or any other country in which we or our subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union, Canada, or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which we or our parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Statement.

Security: We care about the security of your information and use what we believe to be reasonable technical, administrative and physical measures to protect information contained in 5 our system against misuse, loss or alteration. We may use standard security technology to protect information being transferred to our Site.

Please be advised, however, that no security measure, system, or control is infallible. We accordingly do not guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed and disclaim any express or implied warranties, duties or conditions in that regard. If any applicable law imposes on us a duty with respect to these matters that cannot be disclaimed, you acknowledge and agree that our commercially reasonable precautions shall be considered to satisfy that duty unless (and only unless) we have engaged in willful misconduct.

Compromise of information: In the event that the security of any Personal Information under our control is compromised, we will take reasonable steps to investigate and mitigate the situation, including, when and where appropriate, by notifying those individuals whose Personal Information may have been compromised and taking other steps in accordance with applicable laws and regulations.

 

5. YOUR CHOICES ABOUT YOUR INFORMATION AND ACCESS TO YOUR INFORMATION

Commercial and marketing communications: We may provide notifications to you that are required by law or that are for marketing or other business-related purposes. Subject to applicable law, we may provide such notifications to you via email, text message, push notifications, hard copy, or through conspicuous posting on our Site or otherwise through the Services. We reserve the right to determine the form and means of providing notifications to you.

Promotional Emails: We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such promotional email communications, you will be given the option to opt out. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make reasonable efforts to promptly process all unsubscribe requests.

Service-Related Emails: We also may use your Personal Information to send you Services-related informational email communication. You may not opt out of such Services-related communications.

Mobile Device Communications: We may send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.

Cookies: You can choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies performance of the Site may be impaired and certain features may not function at all.

If you have a registered account on our Site, you may access your information and correct, update or delete information by logging into your account. If you have any questions about reviewing or modifying your personal information, you can contact us directly at Compliance@amherst.com.

 

6. “DO NOT TRACK”

Our Services do not respond to Do-Not-Track signals from your browser at this time.

 

7. CHILDREN’S PRIVACY

Our Terms and Conditions require that you must be at least 18 years of age to be eligible to use our Site. We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as Users. The Services are not directed at children under the age of 13. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any Personal Information from or about a child under 13, please contact us at Compliance@amherst.com.

 

8. LINKS TO OTHER WEB SITES, APPLICATIONS AND SERVICES

We are not responsible for the practices employed by websites, applications or services linked to or from the Services, including the information or content contained therein. Please remember that when you use a link to go from the Services to another website or application, our Privacy Statement does not apply to third-party websites, applications or services. Your browsing and interaction on any third-party website, application or service, including those that have a link or advertisement in our Services, are subject to that third party’s own rules and policies.

 

9. NOTICES TO CALIFORNIA, COLORADO, CONNECTICUT, FLORIDA, MONTANA, OREGON, UTAH, AND VIRGINIA RESIDENTS

 

Your California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to ShinetheLight@amherst.com.

State Privacy Acts.

We are currently not subject to the California Privacy Rights Act, the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, the Florida Digital Bill of Rights, the Montana Consumer Data Privacy Act, the Oregon Consumer Privacy Act, the Utah Consumer Privacy Act, or the Virginia Consumer Data Protection Act. If we become subject to any of these laws in the future, we will update this Privacy Policy accordingly.

 

10. NOTICE TO NEVADA RESIDENTS

We adopt this notice to comply specifically with the Nevada Privacy Law and any terms defined in the Nevada Privacy Law have the same meaning when used in this notice (“Nevada Notice”). The Nevada Privacy Law provides residents of the state of Nevada with specific rights regarding their personal information. As such, this Nevada Notice applies solely to those individuals (for purposes of this section, “you” or “your”) who are Nevada residents. This section describes a Nevada resident’s rights and explains how to exercise those rights.

We do not sell personal information for monetary consideration. If you would like to instruct us to not sell your personal information in the future, you (or your authorized representative) may email us at NevadaPrivacy@amherst.com with Nevada Do Not Sell in the subject line.

 

11. RESIDENTS OF TEXAS: PRIVACY RIGHTS NOTICE

If you are a resident of Texas, the following provisions may apply to our processing of information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”) subject to the Texas Data Privacy and Security Act (the “TX Privacy Law”).

A ‘Consumer’ is defined as a resident of the state who is acting in an individual or household capacity, but this excludes state residents who are acting in an employment capacity (as one of our current, former or prospective employees) or in a commercial capacity (as an employee, owner, director, officer, etc. of an entity communicating with us in that context). As a result, if you reside in one of these states and have interacted with us in an employment or commercial capacity you are not provided the rights described below by the TX Privacy Law.

For Consumers, the provisions of this section prevail over any conflicting provisions of this Privacy Statement. We adopt this section of our Privacy Statement to comply with the TX Privacy Law of and any terms defined in the TX Privacy Law have the meaning set forth in the law.

Information Collected

We collect personal information from you when you interact with us online through our Website or offline. This includes information that you provide to us directly, information we collect from you automatically, information that we collect when you interact with us such as through your online postings, and information that we may collect from third parties such as service providers, affiliated companies, marketing, or data partners, or other third parties with whom you interact. Not all information is collected from everyone who interacts with us.

During the past 12 months, we may have collected the following categories of personal information:

1. Identifiers such as contact information (your name, address, phone number, email or postal address), Unique Personal Identifiers (that may include but are not limited to your legal name or preferred alias and online identifiers like user account names), an encrypted version of your password, communications.
2. Electronic network activity information such as the internet protocol (IP) address collected from your computers and mobile devices, and information about what you do online, including your interactions with our website, through the use of cookies and similar technologies, system logs, and analytics monitoring.
3. Inferences we make about you or your interests based on analysis of other information we have collected.
4. General location information.
5. Sensitive data (collected with your consent) such as personal data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexuality, or citizenship or immigration status which we collect only for purposes of complying with anti-discrimination laws; genetic or biometric data that is processed for the purpose of uniquely identifying an individual; and precise geolocation data (within a radius of 1,750 feet) or information about a known child.
6. Other types of personal information that we may disclose to you prior to the point of first collection.

Purposes for Processing Personal Information

We process your information for the purposes described in Section 2 (How We Use Your Information) above.

Processing Sensitive Personal Information. We collect and process Sensitive Personal Information for the purposes disclosed herein and at the time we collect this information. We do not process or disclose this information for purposes other than the purpose for which it was originally collected unless required by law. The following are the purposes for which we may process sensitive personal information:

1. To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
2. To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
3. To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
4. To ensure the physical safety of natural persons.
5. To perform services on behalf of our business.
6. To verify or maintain the quality or safety of products or services that we own or control, and to improve, upgrade, or enhance such products or services.
7. To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Consumers’ Rights and Choices.

This section describes Texas Consumers’ rights under the TX Privacy Law, explains how to exercise those rights, and provides information about the response timing and format and your rights to appeal our decisions.

A. Access to Information and Data Portability Rights

Consumers have the right to request that we confirm that we hold information about you and give you access to that information upon request. Consumers also have the right to request a copy of the specific pieces of personal information we collected about you. Once we receive and confirm your verifiable Consumer request, we will disclose to you:

1. Confirmation that we collected personal information we collected about you and how you may access that information.
2. The specific pieces of personal information we collected about you. Please note that this disclosure will not include data generated to help ensure security and integrity or as prescribed by regulation. We will endeavor to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy to your registered account, if you have registered an account with us.

B. Consumers’ Deletion Request Rights

Consumers have the right to request that we delete any of their personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm a verifiable Consumer request, we will delete your personal information from our records, unless we are required by law or regulation to retain it. We may deny your deletion request if retaining the information is necessary for us to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities and to help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.
6. Comply with a legal obligation.
7. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

C. Consumers’ Information Correction Rights

Consumers have the right to request that we correct information that we hold which is inaccurate. We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections. In some cases, for instance if you have an account with us, you can update your information by logging into your account.

D. Consumers’ Opt-Out Rights

1. Do Not Sell My Personal Information. We do not sell personal information. You have the right, at any time, to direct us to not sell your personal information.
2. Do Not Process My Personal Information for Targeted Advertising. We do not engage in targeted advertising. Consumers have the right at any time to opt out of having your personal information processed for targeted advertisements. When Consumers opt out we will not share their personal information with others that they can use to send the Consumer targeted advertisements and we will not use information we obtain over time from Consumers’ activities with third party companies to show advertisements. We can still use information that we receive from your interactions with us to select advertisements we think may be of interest to you.
3. Do not Profile. We do not engage in profiling. Consumers have the right to tell us not to use any form of solely automated processing performed on personal data to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements in order for us to make decisions resulting in the provision or denial of credit, housing or insurance services.

Exercising Consumer Rights

A. Making a Consumer Request.

Consumers may make a verifiable Consumer request only twice within a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.

1. Access, Portability, Correction and Deletion. To exercise the access, portability, correction, and deletion rights Texas Consumers may contact us by email at TexasPrivacy@amherst.com or through our TX Privacy Webform Texas Data Privacy Request Webform – Form by Asana. We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected personal information) and will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be.
2. Opt-Out Rights. We do not engage in the selling of personal information, use of personal information for targeted advertising, profiling, or using sensitive personal information outside of legally permitted uses. Therefore, you do not need to opt out of these activities.

B. Using an Authorized Agent.

You may designate another person to serve as your authorized agent and to act on your behalf to submit opt out requests. We may require the agent to submit proof to us that they have been authorized to make requests on your behalf.

C. Our Responses.

We will endeavor to respond within forty-five (45) days of receipt of your request, but if we require more time (up to an additional forty-five (45) days) we will notify you of our need for additional time.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance (e.g. Microsoft Excel file and/or Adobe PDF file).

For requests for deletion of your information, please understand that TX Privacy Law permits us to retain certain information and not delete it under certain circumstances noted above in the description of Information Deletion Request Rights.

We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm that the personal information relates to you.

We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you as a result of your exercise of any of these rights.

Retention of Personal Information

We will store Consumer personal information in a form which permits us to identify Consumers, for as long as necessary for the purpose for which the personal information is processed. We may retain and use such personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. We retain information Consumers provide in connection with requests made under the TX Privacy Laws for a period of two (2) years.

Appealing Denied Requests

1. If we have denied your Consumer request, you can file an appeal with us. To file an appeal with us, either:Email TexasPrivacy@amherst.com and request an appeal of the prior decision; or

Submit an appeal request through our TX Privacy Webform https://form.asana.com/?k=AKDV3vvisXbXC9x5EvBz7Q&d=28384579903503. We will respond to you in writing within sixty (60) days explaining the reasons for our decisions. If we deny your appeal you can contact the Texas Attorney General at:

Office of Attorney General
PO Box 12548
Austin, TX 78711-2548

Or via OAG webform at www.texasattorneygeneral.gov/consumercomplaintportal/.

 

12. HOW TO CONTACT US

If you have any questions about this Privacy Statement or the Services, please contact us using the Contact Us page or at Compliance@amherst.com. You may write to us at 5001 Plaza on the Lake, Ste 200, Austin, TX 78738, Attn: Legal & Compliance Dept.

 

13. CHANGES TO OUR PRIVACY STATEMENT

We may modify or update this Privacy Statement from time to time to reflect the changes in our business and practices. When we change this Privacy Statement in a material manner, we will update the ‘last modified’ date at the bottom of this page. We encourage you to review this Privacy Statement whenever you use our Services in order to stay informed about our information practices.

To the extent not prohibited by law, any amendment or update to this Privacy Statement will apply to Personal Information that we already have collected and to any Personal Information that we subsequently may obtain. When required by applicable law, however, we may provide you with advance notice of any changes to this Privacy Statement and with an opportunity to object to such changes. If you exercise your right to object, the changes will not become effective with respect to your Personal Information, but your ability to use our Services may be terminated or impaired. We will explicitly notify you of the consequences of objection or non-objection to the extent and in the manner required by law.

This Privacy Statement was last modified on August 6,2024.