Your Choices and Rights
- Changes to Your Marketing Preferences: You can change your marketing preferences by:
- Using the unsubscribe function in the email you
receive from us;
- Logging into your account (if the Service offers an
account with such functionality); or
- Contacting us as set forth under “How Can You
Contact Us?” below.
- Withdrawing Your Consent: You may withdraw any consent you have provided to us
to Process your information at any time.
- Accessing your Information: In accordance with applicable law, you may access the
Personal Information we Process about you. Any request to access or obtain
copies of your Personal Information must be made in writing by contacting us as
set forth under “How Can You Contact Us?” below. We may also ask you to
log into your account, to verify your identity and to provide further details
relating to your request.
- Correcting your Information: We will take reasonable steps to ensure the accuracy
of the Personal Information we retain about you. It is your responsibility to
ensure you submit true, accurate, and complete information to us, and timely
update us in the event this information changes. You may request that any
inaccurate or incomplete Personal Information held by us or on our behalf is
corrected, by contacting us as set forth under “How Can You Contact Us?” below.
- Deleting your Information: Under certain circumstances, you may request we delete
Personal Information we hold about you by contacting us as set forth under “How
Can You Contact Us?” below. We will assess your request and determine,
under applicable law, whether we are required to delete this information.
- Objecting to Processing: If you would like us to stop the Processing of your
Personal Information, you can request this by contacting us as set forth under
“How Can You Contact Us?” below. We will assess your request and
determine, under applicable law, whether we have any justification for the
continued Processing.
- Transferring your Information: Under certain circumstances, you may
receive your Personal Information in a format that allows you to send it to
another company or to direct us to transfer it directly to another company.
Your South African Rights
- Applicability of this Section: This section of Our Privacy Notice applies specifically to
persons located in South Africa. If you are located in South Africa, to the
extent of any inconsistency between this section of Our Privacy Notice and the
other sections of Our Privacy Notice, this section will prevail.
- Protection of Personal Information
Act 2013: For persons located in South
Africa, this Privacy Notice shall be read in conjunction with the Protection of
Personal Information Act, 2013 (No. 4 of 2013) (“POPIA”).
- Scope of Privacy Notice: In South Africa, this Privacy Notice applies to
information relating to an identifiable, living, natural person, and where
applicable, an identifiable, existing juristic person.
- Consent to Process Personal
Information: By providing
Personal Information to Us, you consent to Our collection, use and disclosure
of your Personal Information in accordance with this Privacy Notice and any
other arrangements that apply between us. We may change Our Privacy Notice from
time to time by publishing changes to it on Our website. We encourage you to
check Our website periodically to ensure that you are aware of Our current
Privacy Notice.
- Personal Information Collection
Method: In the course of providing you
with products or services, We collect Personal Information in a variety of
ways. Unless it is unreasonable or impracticable to do so, We collect your
Personal Information from you directly. In some cases, however, We will collect
information about you from a third party. For example, We may collect Personal
Information about you from third party service providers, affiliates or agents
assisting Us to provide products or services to you.
- Other Entities: The privacy and collection practices of entities to which
We disclose Personal Information are governed by their own privacy policies and
collection notices.
- Overseas disclosure of Personal Information
- As
part of a global business, We may disclose your Personal Information to
recipients that are located outside of South Africa.
- When you provide Personal Information to Us, you
consent to the disclosure of such Personal Information outside of South Africa
and acknowledge that We are not required to ensure that overseas recipients
handle that Personal Information in compliance with the POPIA and the
associated Conditions for Lawful Processing of Personal Information (“Conditions”). We will, however, take
reasonable steps to ensure that any overseas recipient will deal with such
Personal Information in a way that is consistent with the Conditions.
- Correcting Personal Information
- You
accept the responsibility for keeping Personal Information that you
provide to Us up to date, and undertake to inform Us of any changes to
Personal Information. If you believe that the Personal Information we
hold about you is inaccurate or incomplete, please contact Us and we will
use all reasonable efforts to correct the information.
- If,
on receipt of a request from you to correct or delete your Personal
Information, We do not believe the Personal Information We hold about you
to be incorrect, We will retain your Personal Information in its original
form but We will take reasonable steps at your request to add a statement
to the Personal Information stating that you believe the information is
inaccurate, incomplete or out of date.
- Consequence of Withdrawal of Consent: If the processing of your Personal Information
is based on consent, you may withdraw consent granted at any time. We will
delete your Personal Information within a reasonable time after you withdraw
your consent, but We may not be able to continue providing the Services to you
thereafter. Please note that the withdrawal of your consent does not affect Our
right to continue to collect, use and disclose your Personal Information where
such collection, use and disclosure without consent is permitted or required
under the applicable laws.
- Accessing your Information: If you wish to access your Personal Information you are able
to do so by:
- Logging
into your account (if the Service offers an account with such
functionality) and viewing a copy of your Personal Information; or
- Contacting us as set forth under “How Can You Contact Us?” below.
Your Nevada Privacy Rights
Notice to Nevada Residents: If you are a resident
of Nevada, under certain circumstances, Nevada Civil Code Section NRS 603A.340
allows you to request operators of websites not to sell your Personal
Information. To make such a request, please send an email to our Privacy Group at compliance@rci.com or
send a letter to (please indicate the Panorama entity or brand you typically do
business with):
RCI
South Africa
The Core
Corner Kikuyu & Leeuwkop
Roads
Sunninghill, South Africa, 2157
Your California Privacy Rights
- Shine
the Light Law: If
you are a resident of California, California Civil Code Section 1798.83
allows you to request information regarding the Personal Information we
collected and third parties to whom we disclosed your Personal Information
for the third parties' direct marketing purposes during the preceding
calendar year. To send this request, you may contact us using one of the
methods in the “How Can
You Contact Us?” section of this Privacy Notice.
- California Consumer Privacy Act (“CCPA”): This section 2 is intended to satisfy the
requirements of the California Consumer Privacy Act (“CCPA”). This section supplements our Privacy Notice. The rights herein
are in addition to any other rights applicable to you in this Privacy Notice. Where
there is a conflict between this section and other provisions of this Privacy
Notice, this section will prevail for California residents and their rights
under the CCPA and applicable California law.
- Personal Information Definition: For the CCPA, “Personal Information” is any information that identifies,
relates to, describes, is reasonably capable of being associated with,
or could reasonably be linked, directly or indirectly, with a particular
individual or household.
- Exclusions:Some Personal Information is not subject to the CCPA such as consumer
credit reports and background checks, publicly available data lawfully
made available from state or federal government records, Personal
Information governed by the Gramm-Leach Bliley Act, the Fair Credit
Reporting Act, the California Financial Information Privacy Act, and any
other Personal Information exempt from the CCPA. This CCPA section does
not apply to our employees. A separate privacy notice applies to our employees.
- The Categories of Personal Information We
Collect and Why We Collect Them. Generally, where applicable, in our role as a “Business” under CCPA, we may
collect the following categories of Personal Information (as set forth in the
CCPA) about you for the following purposes:
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Personal Information Category
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Identifiers: Identifiers such as your
real name, alias, title, military or other service rank, postal address, unique
personal identifier, online identifier, Internet Protocol address, email
address, account name, social security number, driver's license number,
passport number, account number, rewards program number, and other similar
identifiers.
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Purposes of Collection
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We may collect this information to
establish a business record of you, setup rewards and other accounts, create
login credentials for you, and for similar reasons.
We
may collect this information to communicate to you about your purchases,
transactions, contracts, our business relationship with you, and for similar
reasons.
We
may collect this information to provide you with surveys for quality
assurance, product development and more.
We
may collect this information to facilitate communications to you regarding
products/services that may be of interest to you.
We
may collect this information to provide a list to resorts, homeowner's associations
("HOAs"), and third
party partners related to your transactions, election activities, ownership
and more.
We
may collect this information to verify your identity such as when you request
access to your Personal Information or apply for financing.
We
may collect this information such as government id related information in
order to process your financing application or provide information to a
travel provider such as an airline pertaining to your reservation.
We
may collect this information to provide a list of your emergency contacts.
We
may collect this information to meet a legal requirement such as recording a
title or similar functions.
We
may collect your signature on documents like contracts, financing terms,
waivers, etc.
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Personal Information Category
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Customer Records: Paper and electronic records
containing Personal Information, such as name, signature, physical
characteristics or description, address, telephone number, education, current
employment, employment history, social security number, passport number,
driver’s license or state identification number, insurance policy number,
bank account number, credit or debit card number or any other financial or
payment information, medical information or health insurance information.
Some information in this category may overlap with other categories.
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Purposes of Collection
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We
may collect this information to set up ownership, membership, online and
other accounts you request.
We
may collect this information to process and/or administer your financing
applications and financing, your contracts, your reservations, your loyalty
and/or rewards accounts, and more.
We
may collect this information to determine your eligibility for certain
products or services.
We
may collect this information to process payments and purchases of any of our
products or services.
We
may collect this information to verify your identity such as when you request
access to your Personal Information or apply for financing.
We
may collect this information if you engage in certain physical, sports or
similar activities at our resorts and other properties.
We
may collect this information to detect and prevent fraud.
We may collect this
information to comply with applicable laws and to meet other legal
obligations.
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Personal Information Category
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Commercial
Information: Records
of personal property, products or services purchased, obtained, or considered,
or other purchasing or consuming histories or tendencies.
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Purposes of Collection
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We may collect this information to
process and/or administer your financing applications and financing, your
contracts, your reservations, your loyalty and/or rewards accounts, and more.
We
may collect this information to personalize your services/products, provide
helpful suggestions, respond to your commercial inquiries, and facilitate
communications to you of products/services and related features that may be
of interest to you.
We
may collect this information to create efficiencies in managing reservations
and recurring commercial interactions with you or otherwise managing our
ongoing business relationship.
We
may collect this information to maintain a record of your consuming history
preferences and tendencies to better serve you, to personalize an experience
for you, and to meet other needs of offering, providing and maintaining an
ongoing service relationship with you.
We
may collect your survey answers about events, products/services and more for
quality assurance, product improvement, and to facilitate marketing that may
be of interest to you.
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Personal Information Category
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Protected
Classifications: characteristics of protected classifications under
California or federal law such as race, color, sex, age, religion, national
origin, disability, citizenship status, and genetic information.
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Purposes of Collection
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We may collect this information
where needed for a legal or financial document such as when we collect your
marital status for a financing application.
We
may collect this information where needed for a reservation, such as where we
may need your gender to report to the airlines. We may also collect this
information like gender to address you with the proper salutation.
We
may collect this information to provide you with the proper accommodations or
assistance such as when you notify us of health related accommodations you
require related to a reservation.
We
may collect additional information in this category as appropriate.
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Personal Information Category
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Biometric
Information: physiological,
biological or behavioral characteristics that can be used alone or in
combination with each other to establish individual identity, including
fingerprint, faceprint, hand, palm, and voice recordings, and health or
exercise data that contain identifying information.
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Purposes of Collection
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We
may collect biometric information in order for you to access portions of a
resort or property or to assist in a law enforcement investigation.
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Personal Information Category
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Internet
Activity: Internet
or other electronic network activity information, including, but not limited
to, browsing history, search history, and information regarding a resident's
interaction with an internet website, application, or advertisement, as well
as physical and network access logs and other network activity information
related to your use of any company device, network or other information
resource.
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Purposes of Collection
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We
may collect this information to improve our website functionality, improve
transaction throughput, and personalize your experience. We may collect this
information to determine what interests you to facilitate targeted
communications of products and services to you. We may collect this
information to judge the effectiveness of any online marketing campaigns.
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Personal Information Category
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Geolocation
Data: General
or precise geographic location information about a particular individual or
device.
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Purposes of Collection
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We may collect your postal address
and/or the location associated with your device to create demographic
analysis of visits to our site, prevent fraud and promote interest in our
products to better market to and understand our customers.
Your location may be used to send
you messages or notifications depending on your jurisdiction and settings.
We
may collect this information because of differences in jurisdictional laws to
be sure we are compliant in our presentation of content.
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Personal Information Category
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Audio/Visual
Data: audio,
electronic, visual, thermal, olfactory, or similar information such as, CCTV
images and photographs, and audio recordings (e.g., recorded meetings).
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Purposes of Collection
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We may collect this information
for quality assurance of product/service presentations or communications,
when you pose for videos/photos or provide audio recordings at our resorts or
to us in any manner in order to improve our products and services, when you
participate in activities or excursions or attend other events as part of
service delivery.
We
may collect this information in public areas of our facilities and online to
provide safe and secure facilities and to ensure quality assurance.
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Personal Information Category
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Employment
History: professional
or employment-related information.
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Purposes of Collection
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We
may collect details of your employment history such as job title and length
of time at your employment to process a financing application. We may collect
employment history as part of a larger analysis of you and what
products/services would be well suited for you. We may collect details of
your employment history as part of your credentials if you run for an elected
position within the HOA of your vacation ownership property.
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Personal Information
Category
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Education Information: information
about education history or background that is not publicly available
personally identifiable information as defined in the federal Family
Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part
99).
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Purposes of Collection
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For
example, we may collect this information in order to process financing, in
order to match your potential interest and likelihood of purchasing certain
products/services, and as part of any office election you may run for as a
candidate related to an HOA.
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Personal Information Category
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Profiles
and Inferences: inferences
drawn from any of the information identified above to create a profile about
a resident reflecting the resident's preferences, characteristics, psychological
trends, predispositions, behavior, attitudes, intelligence, abilities, and
aptitudes.
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Purposes of Collection
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For
example, we may infer what products or services may interest you, your
predicted attachment to your purchased products, your likelihood of
purchasing other products, your likelihood of exacting contract and financing
terms, and more. We may collect demographic information about you, such as
your age, income, etc.
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OTHER
PURPOSES FOR COLLECTING AND USING YOUR PERSONAL INFORMATION: Generally, we may use all of the above
categories of Personal Information for the following purposes where applicable:
- Security and Monitoring. In order to monitor and secure our resources, network, premises and assets, including:
- Monitoring for preventing, investigating, and responding to
security and privacy incidents
- Providing and
managing access to physical and technical access controls
- Monitoring activities,
access and use to ensure the security and functioning of our systems and assets
- Securing our
offices, premises and physical assets, including through the use of electronic
access systems and video monitoring
- Auditing,
reporting corporate governance, and internal operations. We process Personal
Information for the purposes of performing audits of our business
operations, performing security reviews, ensuring we are meeting legal
obligations, managing your business record, and other auditing functions.
- M&A
and Other Business Transactions. For purposes of planning, due diligence and
implementation of commercial transactions, for example mergers,
acquisitions, asset sales or transfers, bankruptcy or reorganization or
other similar business transactions.
- Defending
and Protecting Rights. In
order to protect and defend our rights and interests and those of third parties,
including to manage and respond to employee and other legal disputes, to
respond to legal claims or disputes, and to otherwise establish, defend
or protect our rights or interests, or the rights, interests, health or
safety of others, including in the context of anticipated or actual
litigation with third parties.
- Compliance
with Applicable Legal Obligations. Relating to compliance with applicable legal
obligations (such responding to subpoenas and court orders) as well as
assessments, reviews and reporting relating to such legal obligations.
a. WHERE
DO WE GET YOUR PERSONAL INFORMATION: We may collect all of the Personal Information
categories above primarily from you such as when you fill out a form,
contact us, submit documents to us, use our Websites or Mobile Apps, apply
for financing, and interact with us in other ways. We may collect it from within
the Panorama Group of Companies, T + L Affiliates, third party partners or
data management companies. We may collect it from social media accounts
such as when you connect to our Websites through such an account. We may
collect it from travel agents who provide it to us on your behalf or other
persons who provide your information.
b. TO
WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?: We disclose Personal Information
to T + L Affiliates, any entity within the Panorama Group of Companies, vendors
and service providers, legal and regulatory agencies under certain
circumstances, third party product and service providers, third party
partners, and others under certain circumstances. Please see the “When
We Disclose Your Information” section for more.
c. SELLING YOUR PERSONAL
INFORMATION:
Based on the CCPA's broad definition of "sale," certain data
collection on our sites and applications by third parties for purposes of
internet-based advertising and social media tools, as well as some other
activities involving the disclosure of personal information to another
business or a third party, may be a "sale" under the CCPA even
if we do not share your information for money. Under some circumstances as
described below, we may "sell" or license your Personal
Information under this broad definition.
d. Partners: We may sell your Personal
Information to sweepstakes, contest, promotion partners or other third
parties so that they can market to you. This will only occur if you agree
to participate in such a promotion and will be subject to your marketing
preferences.
e. T + L Affiliates and Entities
within the Panorama Group of Companies: We may sell your Personal Information to T + L Affiliates
or entities within the Panorama Group of Companies so that they can market
to you their products and services provided that such sharing is subject
to your marketing preferences.
- Internet-Based Advertising/Social Media Tool: To
the extent certain information collection on our sites and through third-party
applications is considered a "sale" under the CCPA, you may either
opt-out through the "Do Not Sell My Information" link or as provided
in the section "Other information
we collect about you" in our general Privacy Notice.
- Opt-Out: You
have the right to opt-out of having your Personal Information sold. Please see
the section of this Privacy Notice: "California
Rights". Once we share your Personal Information with another business
or a third party for such purposes, the information shared becomes subject to
such other business or third party's privacy practices.
f. California
Rights: If you are a California resident, you have certain rights with
respect to your Personal Information as set forth below:
- Right
to Know: You
have a right to know what Personal Information Categories we have
collected, used, disclosed or sold about you in the previous 12 months
and the purposes of such actions. You have a right to know the sources of
collection of such information and to whom we have disclosed it to for
business purposes or a sale. You also have a right to receive a list of
the Personal Information we have collected about you in the last 12
months from the date of your request. You may request any or all of this
information up to two times in a 12-month period. You may exercise this
right by filling out and submitting a Privacy Rights Request Form where
one is available (See ‘California Privacy Rights Request Form Link'
below) or by contacting us using one of the methods listed in the “How Can You Contact Us?”
section of this Privacy Notice.
- Right
to Delete: You
have a right to instruct us to delete certain Personal Information we
hold about you. We will assess your request and determine, under the
CCPA, what Personal Information we are required to delete. If we retain
any Personal Information, we will notify you of what we have retained and
why. For information we delete, we will notify you of the method of
deletion. You may exercise this right by filling out and submitting a
Privacy Rights Request Form where one is available (See ‘California
Privacy Rights Request Form Link' below) or by contacting us using one of
the methods listed in the “How Can You Contact Us?” section of this
Privacy Notice.
- Right to Opt-Out of Sale of Your Personal
Information: You have the right to instruct Us not to sell your Personal
Information. You may exercise this right by filling out and submitting
this Opt-Out Request Form (link here) or by contacting Us using one of
the methods listed in the “How Can You Contact Us?” section of this
Privacy Notice.
- Nondiscrimination: You shall not incur or
be subject to any price or quality of service difference from us for
exercising any of your rights under the CCPA. If you feel you have been
treated unfairly for exercising any of your rights under the CCPA, please
contact us immediately using one of the methods listed in the “How Can You Contact Us?”
section of this Privacy Notice.
- Verification: We will require certain
information from you to verify your identity as the requestor. Generally,
we will ask you information that we have already collected about you to
provide this verification. For instance, if you submit a “Right to Know”
request, we may ask your name, address, email address, account number if
applicable, and phone number. We reserve the right to ask additional
questions and/or to contact you directly if in our discretion we
determine we need additional verification.
- Agents: You may have an agent
exercise your rights on your behalf. If an agent provides a Power of
Attorney in compliance with California Probate Code Sections 4000-4464, we
will process such request. If however, your agent does not provide such
Power of Attorney, we will need you to provide written permission to us of
the agent's right to exercise your rights in this section on your behalf.
Please include your full name, the address and email associated with your
account with us, your member number if applicable, the agent's full name
and address, and the agent's email. Please send this permission to privacy@rci.com. Furthermore,
in addition to your written permission, we may contact you and/or your
agent for further verification of your request.
California
Privacy Rights Request Form Link:
Access/Delete Form
How Can You Contact Us?
If after reviewing this Privacy Notice, you have any questions, complaints
or privacy concerns, or would like to make any requests in relation to your
Personal Information, or obtain further information on safeguards used for
international transfers, please send an email to our Privacy Group at compliance@rci.com or send a letter to
(please indicate the entity within the Panorama Group of Companies or brand you
typically do business with):
RCI South Africa
The Core
Corner Kikuyu & Leeuwkop Roads
Sunninghill, South Africa, 2157
If you have a complaint or concern about how we Process your Personal Information, we will work to address such concern(s). You may also direct your complaint/concern to the applicable data protection authority.