Privacy Policy

 

Last Updated on February 13, 2022. This Privacy Policy is effective  February 13, 2022 for all users.

 

This Privacy Policy discloses our policies on the collection, use, and disclosure of information about you in connection with your use of our services, including those offered through our websites, communications (e.g., emails, phone calls, and texts), and mobile applications (collectively, the "Service"). The terms "us", "we""our", “SafeCare” and "100 SafeCare Hospitals” refer to: The SafeCare Group, LLC, a limited liability company with its headquarters in Lexington, Kentucky. For convenience, the terms "user", "you""your" refer to all users of the Service, including, without limitation, anyone that accesses or visits the Service and view only publicly-available content; individuals who have signed up to use the Service; and hospitals and other providers of healthcare services and persons working on their behalves who input or post or edit profiles and other content, materials and information related to them (collectively “Hospitals”).

 

BY VISITING THE SERVICE, OR BY SIGNING UP, ACCESSING, AND/OR USING THE SERVICE, YOU AGREE TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND YOU HEREBY CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU CANNOT USE THE SERVICE. IF YOU USE THE SERVICE ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF.

 

TABLE OF CONTENTS

1.    INFORMATION COLLECTED AND HOW WE USE IT

2.    SUBMISSION OF REVIEWS, RATINGS, AND COMMENTS

3.    COOKIES

4.    THIRD PARTIES

5.    CONTROLLING YOUR PERSONAL DATA

6.    data integrity

7.    HIPAA AND PHI

8.    DATA RETENTION AND ACCOUNT TERMINATION

9.    YOUR CHOICES

10.CHILDREN

11.information sECURITY

12.CONTACT INFORMATION

13.MODIFICATIONS TO THIS PRIVACY POLICY

14.CALIFORNIA PRIVACY RIGHTS

15.NEVADA PRIVACY RIGHTS

16.IMPORTANT NOTICE TO NON-U.S. RESIDENTS

 

1. INFORMATION COLLECTED AND HOW WE USE IT

In the course of operating the Service we may collect and store information about you in connection with your use of the Service, including any information you transmit to or through the Service. We use that information to provide the Service’s functionality, fulfill your requests, improve the Service’s quality, engage in audit, research and analysis to troubleshoot, maintain, protect, and improve the Service. We also that information to personalize your experience, track usage of the Service, provide feedback to third party businesses that are listed on the Service, display relevant advertising, market the Service, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Service, and comply with legal obligations. Even when we do not retain such information, it still must be transmitted to our servers initially and stored long enough to process. Please also note:

A.    Account Information: If you create a 100 SafeCare Hospitals account, we may store and use the information you provide during that process, such as your full name, email address, zip code, physical address, and other information you may provide with your account, such as your gender, phone number, and birth date. We may publicly display your first name and last initial, as well as any photo or other content you submit through the registration process, as part of your account profile. Your account information may also contain sensitive personal information, including any confidential health information such as the hospitals, doctors, other healthcare specialists, professionals, other healthcare providers, organizations, or agents or affiliates thereof (collectively, “Hospitals”) you have visited, your reasons for visit, your dates of visit, your medical history, and other medical and health information that you voluntarily provide. You can modify some of the information associated with your account through your account settings. If you believe that someone has created an unauthorized account depicting you or your likeness, you can request its removal by flagging it.

B.     Contacts: You can invite others to join or become your friend on 100 SafeCare Hospitals by providing us with their contact information, or by allowing us to access your contacts from your computer, mobile device, or third party sites to select which individuals you want to invite. If you allow us to access your contacts, we may transmit that information to our servers long enough to process your invitations.

C.    Communications: When you sign up for an account or use certain features, you are opting to receive messages from other users, businesses, and 100 SafeCare Hospitals. You can manage some of your messaging preferences through your account settings, but note that you cannot opt out of receiving certain administrative, transactional, or legal messages from 100 SafeCare Hospitals. We may also track your actions in response to the messages you receive from us or through the Service, such as whether you deleted, opened, or forwarded such messages. If you exchange messages with others through the Service, we may store them in order to process and deliver them, allow you to manage them, and we may review and disclose them in connection with investigations related to use of the Service, as well as our efforts to improve the Service. We may not deliver messages that we believe are objectionable, such as spam messages, fraudulent solicitations, or requests to exchange reviews for compensation. If you send or receive messages through the Service via SMS text message, we may log phone numbers, phone carriers, and the date and time that the messages were processed. Carriers may charge recipients for texts that they receive. We may also store information that you provide through communications to us, including from phone calls, letters, emails and other electronic messages, or in person. If you are a representative of a business listed on 100 SafeCare Hospitals, we may contact you, including by phone or email, using the contact information you provide us, make publicly available, or that we have on record for your business. Our calls with you may be monitored and recorded for quality purposes.

D.    Transactions: If you initiate a transaction through the Service, such as a purchase, we may collect and store information about you, such as your name, phone number, address, email, and payment information (such as a credit card number and expiration date), as well as any other information you provide to us, in order to process your transaction, send communications about them to you, and populate forms for future transactions. This information may be shared with third parties, and third parties may share such information with us, for the same purposes. When you submit credit card numbers, we encrypt that information using industry standard technology. If you write reviews about businesses with which you transact through the Service, we may publicly display the fact that you transacted with those businesses.

E.     Activity: We may store information about your use of the Service, such as your search activity, the pages you view, the date and time of your visit, businesses you call using our mobile applications, and reservations, purchases, or transactions you make through the Service. We may also store information that your computer or mobile device may provide to us in connection with your use of the Service, such as your browser type, type of computer or mobile device, browser language, IP address, WiFi information such as SSID, mobile carrier, phone number, unique device identifier, advertising identifier, location (including geolocation, beacon based location, and GPS location), and requested and referring URLs and mobile applications. We may also receive and store your location whenever our mobile applications are running, including when running in the background, if you enable our mobile apps to access such information in the course of using the Service. You may be able to limit or disallow our use of certain location data through your device or browser settings, for example by adjusting the "Location Services" settings for our applications in iOS privacy settings.

F.     Different Devices: You may access the Service through different devices (e.g., your mobile phone or personal computer) and different platforms (e.g., the 100 SafeCare Hospitals website or 100 SafeCare Hospitals mobile apps). The information that we collect and store through those different uses may be cross-referenced and combined, and your contributions through one of 100 SafeCare Hospitals platform will typically be similarly visible and accessible through all other 100 SafeCare Hospitals platforms.

G.    Legal Basis for Processing:  We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for instance, to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations). If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will typically be to operate our Services, communicate with you in relation to our Services, or for our other legitimate commercial interests, for instance, when responding to your queries, to analyze and improve our platform, engage in marketing, or for the purposes of detecting or preventing fraud. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at the address listed below in the “Contact” section.

2. SUBMISSION OF REVIEWS, RATINGS, AND COMMENTS

A.    Public Content: We collect information that you voluntarily contribute as part of the Service. Your contributions to the Service are intended for public consumption and are therefore viewable by the public, including your photos, ratings, reviews, lists, collections, compliments, 100 SafeCare Hospitals posts, and edits to business listing information. Your account profile (e.g., first name, last initial, city, neighborhood, month and year joined, profile photos and friends) is also intended for public consumption, as is some of your other activity through the Service, like how you vote on other people’s contributions (e.g., helpful, not helpful), which contributions you like, where you check-in or where your friends check-in on your behalf, which contributions or users you follow, and which businesses you bookmark. You can limit the public nature of some of these activities through your account settings.

B.    Sharing: We may in our sole discretion share Your Content with others such as your Hospital reviews. If you do not want certain information shared with others, you should not submit such Content, or should not submit Content that contains information or Personal Information you do not want shared in this manner. Once You have submitted Your Content, we reserve the right to publish it in any medium to others.

C.    Developing Products and Services: We may include use of your information in connection with developing and offering to you products and services such as reward and recognition, topics for magazine articles, health education and/or medical error prevention.

3. COOKIES

We, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called "flash cookies"), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology ("Cookies") in connection with your use of the Service, third party websites, and mobile applications. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Service, such as web browser, search preferences, IP address, referring webpage, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session. The purposes for which we use Cookies in the Service include:

A.    Processes: Intended to make the Service work in the way you expect. For example, we use a Cookie that tells us whether you have already signed up for an account.

B.     Authentication, Security, and Compliance: Intended to prevent fraud, protect your data from unauthorized parties, and comply with legal requirements. For example, we use Cookies to determine if you are logged in.

C.    Preferences: Intended to remember information about how you prefer the Service to behave and look. For example, we use a Cookie that tells us whether you have declined to allow us to send push notifications to your phone.

D.    Notifications: Intended to allow or prevent notices of information or options that we think could improve your use of the Service. For example, we use a Cookie that stops us from showing you the signup notification if you have already seen it.

E.     Advertising: Intended to make advertising more relevant to users and more valuable to advertisers. For example, we may use Cookies to serve you interest-based ads, such as ads that are displayed to you based on your visits to other websites, or to tell us if you have recently clicked on an ad.

F.     Analytics: Intended to help us understand how visitors use the Service. For example, we use a Cookie that tells us how our search suggestions correlate to your interactions with the search page.

You can set some Cookie preferences through your device or browser settings, but doing so may affect the functionality of the Service. The method for disabling Cookies may vary by device and browser, but can usually be found in your device or browser preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking. For flash cookies, you can manage your privacy settings by clicking here. Please note that changing any of these settings does not prevent the display of certain advertisements to you. For more information on cookies, including how to control your cookie settings and preferences, visit http://www.allaboutcookies.org.

4. THIRD PARTIES

We may employ third parties to perform services on our behalf to improve the Service, marketing, advertising, and promotional efforts to facilitate transactions, including processing orders by credit card. We do not sell email addresses to third parties. Third parties may receive information about you as follows:

A.    Advertisers: We permits third-party advertising companies and networks to place paid advertisements that may be visible when you visit, use and/or access the Service. We may allow third parties to use Cookies through the Service to collect the same type of information for the same purposes as we do. In doing so, we adhere to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. Third parties may be able to associate the information they collect with other information they have about you from other sources. We do not necessarily have access to or control over the Cookies they use, but you may be able to opt out of some of their practices. Please note that opting out does not prevent the display of all advertisements to you. Additionally, we may share non-personally identifiable information from or about you, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), with third parties in connection with advertising programs and data analytics, including with third parties that help determine the efficacy of such advertising programs by aggregating information they receive from multiple services like the Service. You may be able to limit our sharing of some of this information through your mobile device settings, as described in Section 2 above, or through the Service’s settings.

B.     Content Partners: We allow third party partners to use and display some of the public content available through the Service, such as your photos, reviews, and other information detailed in Section 2 above.

C.    Service Providers: We may rely on third party providers to support or provide some of the services that are available through the Service, such as site moderation. We may also rely on third party providers to perform certain services for us in connection with your use of the Service, such as communications and hosting services, network security, technical and customer support, tracking and reporting functions, quality assurance testing, payment processing, our own marketing of the Service, and other functions. We may share information from or about you with these third party providers so that they can perform their services or complete your requests. These third party providers may share information with us that they obtain from or about you in connection with providing their services or completing your requests. Third party providers may also share this information with their subsidiaries, joint ventures, or other companies under common control. Some of our web pages utilize framing techniques to serve content to you from our third party providers, while preserving the look and feel of the Service. In such cases, please note that the information you provide is being provided to the third party.

D.    Aggregate or Anonymous Information: We may disclose aggregated non-personal information with third parties, such as businesses that are listed on 100 SafeCare Hospitals and content distributors. For example, we may disclose the number of users that have been exposed to or clicked on advertisements. We may also disclose anonymized information about your use on 100 SafeCare Hospitals. For example, if you engage in a transaction in connection with 100 SafeCare Hospitals, we may publicly disclose information about the transaction without providing additional identifying information about you or otherwise disclosing your participation in the transaction.

E.     Business Transfers: We may share information from or about you with our parent companies, subsidiaries, joint ventures, or other companies under common control, in which case we will require them to honor this Privacy Policy. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets. If another company acquires 100 SafeCare Hospitals, or all or substantially all of our assets, that company will possess the same information, and will assume the rights and obligations with respect to that information as described in this Privacy Policy.

F.     Businesses on 100 SafeCare Hospitals: We may share information from or about you (such as your age, gender, and city), your devices, and your use of the Service (such as which businesses you bookmark or call, or if you visit a business’s URL) with businesses listed on 100 SafeCare Hospitals. You may adjust your account settings to increase or decrease the amount of information we share. Keep in mind that businesses may still see your public activity and posts, and may receive information from or about you when you transact or communicate with them, through 100 SafeCare Hospitals or otherwise, regardless of your settings (see Section 1 above). Additionally, if you make a phone call to a business through or in connection with your use of the Service, we may share information about your call with the business that the business would have received had you called them directly, such as the date and time of your call and your phone number. You may be able to limit our ability to collect and share your phone number through your phone’s settings or phone service provider.

G.    Investigations and Legal Disclosures: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure: (a) is reasonably necessary to comply with legal processes and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process or law enforcement requests served on us; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the Service; or (c) protects our rights, reputation, property, or that of our users, affiliates, or the public, such as disclosures in connection with 100 SafeCare Hospitals program; or respond to claims that any posting or other content violates third-party rights. If you flag or otherwise complain to us about content through the Service, we may share the substance of your complaint with the contributor of that content in order to provide an opportunity for the contributor to respond.

H.    Links: The Service may link to third party services, like a business’s URL. Except as set forth herein, we do not share your personal information with them, and are not responsible for their privacy practices. We suggest you read the privacy policies on or applicable to all such third party services. A link to or embedded content from third party services does not mean that we endorse such third party services, the quality or accuracy of information presented on such third party services or the persons or entities associated with such third party services. If you decide to visit such third party services, you are subject to the privacy policy of such third party services as applicable and we are not responsible for the policies and practices of such third party services. We encourage you to contact such third party sites directly if you have any questions about their use of your information, and we encourage you to ask questions before you disclose your information to others.

I.      Third Party Integrations: If  you sign up for, or log into, 100 SafeCare Hospitals using a third party service like Facebook or Google, or link your 100 SafeCare Hospitals account to your account with a third party service like Facebook, Instagram or Twitter, we may receive information about you from such third party service. If you post content to a third party service through the Service, that third party service will also receive that content, which will be visible to anyone that has access to it through that third party service. Some of our web pages utilize framing techniques to serve content to you from our third party partners, while preserving the look and feel of the Service. In such cases, please note that the information you provide may be transmitted directly to the identified third party partner. If you interact with businesses through 100 SafeCare Hospitals, they will receive whatever information you choose to share with them, for example contact information you share through direct messages to the business or your phone number if you call the business.

5. CONTROLLING YOUR PERSONAL DATA

Other users may be able to identify you, or associate you with your account, if you include personal information in the content you post publicly. You can reduce the risk of being personally identified by using the Service pseudonymously, though doing so could detract from the credibility of your contributions to the Service. Please also note that the messages you send or receive using the Service are only private to the extent that both you and the person you are communicating with keep them private. For example, if you send a message to another user, that user may choose to publicly post it. Also, we may access, review, and disclose such messages in connection with investigations related to use of the Service, as well as our efforts to improve the Service.

6. data integrity

We process personal information only for the purposes for which it was collected and in accordance with this Privacy Policy. We must depend on you and our other users to provide, accurate, complete and current personal information and to update or correct their personal information whenever necessary. We do not and cannot monitor or pre-screen the personal information that you provide for accuracy and completeness but take reasonable steps to ensure that we accurately process and maintain the personal information that you provide.

7. HIPAA and PHI

Under a federal law called the Health Insurance Portability and Accountability Act (“HIPAA”), some demographic, health and/or health-related information that the Service collects as part of providing the Service may be considered “protected health information” or “PHI.” Specifically, when the Service receives identifiable information about you from or on behalf of your Hospitals, this information is considered PHI. HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. The Service may only use and disclose your PHI in the ways permitted by your Hospital(s). In addition, your decision to use the Service is entirely voluntary and if you choose to post PHI, you agree that the Service may use and disclose your PHI in the same way it uses and discloses your personal information that is not PHI. You can decline to provide your personal information when you voluntarily provide information in free-form text boxes through the Service or through responses to surveys, questionnaires and the like by not engaging in the activities described above, such as by not posting PHI or by not using the Service. Accordingly, you can determine to a large extent what personal information you wish to share with the Service.

8. DATA RETENTION AND ACCOUNT TERMINATION

You can close your account by clicking here. We will remove certain public posts from view and/or dissociate them from your account profile, but we may retain information about you for the purposes authorized under this Privacy Policy unless prohibited by law. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations. Please note that businesses cannot remove their business listings, ratings, or reviews by closing their accounts.

9. YOUR CHOICES

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features. If you are a registered user of the Service, you can modify certain personal information or account information by logging in and accessing your account. The information you can view, update, and delete may change as the Services change. If you wish to close your account, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations. Please note that businesses cannot remove their business listings, ratings, or reviews by closing their accounts.

10. CHILDREN

The Service is intended for general audiences and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you become aware that a child has provided us with personal information without parental consent, please contact us here and we will endeavor to delete that information from our databases. If we become aware that a child under 13 has provided us with personal information without parental consent, we take steps to remove such information and terminate the child's account.

11. information SECURITY

We take reasonable and appropriate safeguards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

12. CONTACT information

You may contact us online concerning our Privacy Policy, or write to us at the following address:

100 SafeCare Hospitals,

Attn: Data Privacy Manager

1890 Star Shoot Parkway, Suite 170

Lexington, KY 40509

We will take such steps as we deem necessary to confirm your identity before sharing any personal data with you. We will respond to proper and confirmed requests relating to personal data within 30 days, or as otherwise required by applicable law.

13. MODIFICATIONS TO THIS PRIVACY POLICY

We may revise this Privacy Policy from time to time. The most current version of the Privacy Policy will govern our collection, use, and disclosure of information about you and will be located here. We encourage you to check back and review this Privacy Policy periodically for any updates or modifications. Your continued use of the Service will be deemed acceptance of the updated Privacy Policy. By continuing to access or use the Service after those changes become effective, you acknowledge the revised Privacy Policy. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE SERVICE AFTER THE EFFECTIVE DATE OF SUCH CHANGES.

14. CALIFORNIA RESIDENTS: PRIVACY RIGHTS

Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights around 100 SafeCare Hospitals’ collection, use, and sharing of their personal information.

100 SafeCare Hospitals does not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your personal information.

100 SafeCare Hospitals collects various categories of personal information when you use the Service, including identifiers, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information. A more detailed description of the information 100 SafeCare Hospitals collects and how we use it is provided above in Section 1 (Information We Collect and How We Use It). Section 4 (Third Parties) describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances.

If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access that information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow 100 SafeCare Hospitals to retain and use certain personal information notwithstanding your deletion request. You can learn more about how to submit a data rights request through 100 SafeCare Hospitals’ Support Center. You may also send your request by email to here. We will not discriminate against you for exercising your rights under the CCPA. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.

Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at the address listed above in Section 12.

15. NEVADA RESIDENTS: RPRIVACY RIGHTS 

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. 100 SafeCare Hospitals does not sell your personal information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us through the Support Center.

16. IMPORTANT NOTICE TO NON-U.S. RESIDENTS 

The Service is operated in the United States. If you are a European Resident, you have the right to access your personal data, and the right to request that we correct, update, or delete your personal data. You can object to the processing of your personal information, ask us to restrict processing of your personal information, and request portability of your personal information. Additional information regarding your exercise of these rights is available through the Support Center. Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. The Service generally provides you with a reasonable means to view and change your profile information and you can opt-out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you or in your account settings. If you have any questions or comments about the processing of your personal information, you may contact us as described in Section 12 above. We take the privacy of our users seriously and therefore take steps to safeguard your information, including ensuring an adequate level of data protection in accordance with E.U. standards in effect as of the date of this Privacy Policy. These steps include use of the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection laws. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.