This Privacy Statement describes the personal data we collect and/or process (which may include collecting, organizing, structuring, storing, using, or disclosing) to provide products and services offered directly by Zoom Communications, Inc. (“Zoom”) through the Zoom Common Room products and services (the “ZCR Services”).
Zoom Common Room is an enterprise product designed for business customers. Accordingly, this Privacy Statement does not apply to personal data processed on behalf of our ZCR Services customers, which is subject to their respective privacy policies. If you have questions about how and why your personal data is processed by a ZCR Services customer, their legal basis for processing, or requests regarding your personal data, please direct your inquiries to the relevant ZCR Services customer.
Other products or services developed by Zoom are covered under either Zoom's Privacy Statement, which covers the basic Webinar service and is published here, or a separate privacy policy (including those listed here). California residents, please see our California Privacy Notice at Collection, and California & Other U.S. State Privacy Rights sections.
What Personal Data Do We Receive?
How Do We Use Personal Data?
How Do We Share Personal Data?
Privacy Rights and Choices
Children
How to Contact Us
Retention
European Data Protection Specific Information
California & Other U.S. States Notice at Collection
California & Other U.S. State Privacy Rights
Changes to This Privacy Statement
What Personal Data Do We Receive?
Personal data is any information from or about an identified or identifiable person, including information that Zoom can associate with an individual person. We may collect the following categories of personal data in connection with ZCR Services:
- Account Information: Information associated with an account that licenses ZCR Services, which may include administrator name, contact information, account ID, billing and transaction information, and account plan information.
- Business Contact Information: Name, business email address, business phone number, job information, stated locale, industry, and other information that you may provide to us when inquiring about or signing up for ZCR Services or that we may obtain from third party partners.
- Device Information: Information about the computers, phones, and other devices used when interacting with ZCR Services, which may include information about OS version, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or country level), device attributes (like operating system version and battery level), WiFi information, and other device information (like Bluetooth signals).
- Usage Information Regarding ZCR Services: Information about how people and their devices interact with ZCR Services. This includes information about when and how people visit and interact with Zoom’s websites, including what pages are accessed, interaction with website features including Zoom’s website’s virtual chat feature, and whether or not the person signed up for a Zoom product or service. Some usage data collection is optional and may be controlled by your Diagnostic Data Preferences Setting.
- Content from Third-Party Integrations: Account owners and/or their licensed end users can access calendars and other information from third-party services through their Zoom client, if they choose to integrate them. This information is not end-to-end encrypted by Zoom, but Zoom employees do not access the contents of third-party-service calendar entries or other information, unless authorized to, or required for legal, safety, security or support purposes. If account owners and/or their licensed end users integrate their third-party calendars and/or other information with products and services offered or powered by Zoom, then Zoom may collect or process calendar and other information, including content, headers, titles, and metadata, from such third-party services.
- Communications with Zoom: Information about, and contents of, your communications with Zoom in connection with your ZCR Services, including relating to support questions, website virtual chats, your account, feedback provided by users to Zoom about ZCR Services (which are owned by Zoom), and other inquiries.
- Information from Partners: Zoom obtains certain business contact and other personal information about individuals from third-party companies, such as data enrichment services, data licensors, data aggregators, and data brokers. Zoom may also obtain information from third-party advertising partners that deliver ads displayed on ZCR Services, such as whether you clicked on an ad they showed you.
How Do We Use Personal Data?
Zoom uses personal information collected in connection with ZCR Services for the following purposes:
- Provide ZCR Services: To provide ZCR Services to customers and their licensed end users, including to customize ZCR Services and recommendations for accounts of their users. Zoom also uses personal data to determine what ZCR Services may be available in your location. This may also include using personal data for customer support, which may include information you provide through Zoom’s website’s virtual chat feature. We also use personal data to manage our relationships and contracts with ZCR Services customers and others, including billing, compliance with contractual obligations, and related administration.
- Product Research and Development: To develop, test, and improve ZCR Services, and to troubleshoot ZCR Services.
- Marketing and Promotions: To permit Zoom and/or its third party marketing partners to market, advertise, and promote ZCR Services, including based on your product usage, information we receive from third-party partners, or if you visit our websites, information about how and when you visit, and your interactions with them. We may also use this information to provide advertisements to you relating to ZCR Services or to engage third party partners to analyze your interactions on our website or app or to deliver advertising to you.
- Authentication, Integrity, Security, and Safety: To authenticate accounts and activity, detect, investigate, and prevent malicious conduct, fraudulent activity or unsafe experiences, address security threats, protect public safety, and secure ZCR Services.
- Communicate with You: We use personal data (including contact information, and information you provide through Zoom’s website’s virtual chat feature, including the content of the messages) to communicate with you about ZCR Services, including product updates, your account, and changes to our policies and terms. We also use your information to respond to you when you contact us.
- Legal Purposes: To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, protect you, us, and others from fraudulent, malicious, deceptive, abusive, or unlawful activities, and to enforce or investigate potential violations of our Terms of Service or policies.
How Do We Share Personal Data?
Zoom provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):
- Resellers: If an account owner licensed or purchased Zoom products and services from a third-party reseller of Zoom products and services, the reseller may be able to access personal data and content for users, including meetings, webinars, and messages hosted by the account owner.
- ZCR customers: We may sell or share personal information we obtain from third party providers to customers if they utilize the data enrichment aspect of our Services.
- Vendors: Zoom works with third-party service providers to provide, support, and improve ZCR Services and technical infrastructure. Zoom may also work with third-party service providers to provide advertisements and business analytics regarding ZCR Services. These vendors can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to Zoom or as required by law.
- For Legal Purposes: Zoom may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of the Terms of Service, contracts, or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; (4) meet our corporate and social responsibility commitments; (5) protect our and our customers’ rights and property; and (6) resolve disputes and enforce agreements.
- Marketing, Advertising, and Analytics Partners: Zoom uses third-party marketing, advertising, and analytics providers: to provide statistics and analysis about how people are using ZCR Services, including our website; and to provide advertising and marketing for ZCR Services, including targeted advertising based on your use of our website. These third-party partners may receive information about your activities on the ZCR website through third-party cookies and similar technologies placed on the ZCR website. To opt out of our use of third-party cookies that share data with these partners, visit our cookie management tool, available in Cookies Settings. Where required by law, Zoom will first obtain your consent before engaging in the marketing or advertising activities described. Zoom will not share mobile opt-in data or consent collected through text messaging campaigns with third parties, except as necessary to provide the messaging service requested by the user or as required by law.
- Corporate Affiliates: Zoom shares personal information with corporate affiliates to provide integrated and consistent experiences across Zoom products and services and to detect, investigate, and prevent fraud, abuse, and threats to public safety.
- Change of Control: We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of Zoom’s business or assets, including in connection with bankruptcy or similar proceedings.
- Third-Party Developers: If you purchase a third-party app or integration through ZCR, Zoom may share information about the purchase with the third-party developer, to provide the app or integration.
Privacy Rights and Choices
Marketing Communications
If you don’t want to learn about ZCR Services we or our partners offer, you can opt-out of marketing communications in the communication sent to you (for example, via email or SMS), or by emailing privacy@zoom.us. Not all of our communications are for marketing, and you’ll continue to receive messages related to your products and services, such as bills, transactional notices, or customer service. Zoom will not share any mobile data originating from you through a text messaging campaign except with your consent or as necessary to provide you communications about ZCR Services or services that you requested.
Data Rights
If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California or another U.S. state with an applicable privacy law, please refer to the respective dedicated sections below.
Under certain laws, we are registered as a data broker, and with respect to our data enrichment offerings, you may request that we not sell your data. Residents of Texas can find more information about Texas data broker rules here.
Otherwise, at your request, and as required by applicable law, we will:
- Inform you of what personal data we have about you that is under our control;
- Opt you out of the sharing of your personal data;
- Opt you out of the sale of personal data in our possession, custody or control. We only engage in the sale of personal data for monetary consideration through our data enrichment offerings through ZCR;
- Amend or correct such personal data or any previous privacy preferences you selected, or direct you to applicable tools; and/or
- Delete such personal data or direct you to applicable tools.
In order to exercise any of your rights as to personal data controlled by Zoom and governed by this ZCR Privacy Statement, please click here. Where legally permitted, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others.
Children
Zoom does not allow children under the age of 18 to sign up for a ZCR account.
To exercise your rights, please click here. If you have any privacy-related questions or comments related to this Privacy Statement, please send an email to privacy@zoom.us.
You can also contact us by writing to the following address:
Zoom Communications, Inc.
Attention: Data Protection Officer
55 Almaden Blvd, Suite 600
San Jose, CA 95113
Or to our representative in the EU or UK:
Workvivo Limited
Attention: Zoom EU Representative
4th Floor, City Quarter,
Lapps Quay,
Cork
T12W832
Republic of Ireland
Email: privacy@zoom.us
ZVC UK Ltd.
Attention: Zoom UK Representative
Part Level 6, Mid City Place,
71 High Holborn,
London
WC1V 6EA
United Kingdom
Email: privacy@zoom.us
You can contact our Data Protection Officer by sending an email to privacy@zoom.us.
Retention
We retain personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law.
The criteria used to determine our retention periods include the following:
- The length of time we have an ongoing relationship with you and provide ZCR Services to you (for example, for as long as you have an account with us or keep using our products);
- Whether account owners modify or their users delete information through their accounts;
- Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).
Data Subjects Rights
If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:
- Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;
- Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
- Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;
- Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;
- Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
To exercise your rights, please click here. If you have any other questions about our use of your personal data, please send a request at the contact details specified in the How to Contact Us section of this Privacy Statement. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.
You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.
Legal Basis for Processing Personal Data
We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when Zoom processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:
- As necessary for our contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Zoom products and services, features and services to account owners, their users, and those they invite to join meetings and webinars hosted on their accounts, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all products and services;
- Consistent with specific revocable consents: We rely on your prior consent in order to utilize cookies and similar technologies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage. You have the right to withdraw your consent at any time by visiting our cookie management tool, available in Cookies Settings;
- As necessary to comply with our legal obligations: We process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) and compliance with privacy laws;
- To protect your vital interests or those of others: We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
- As necessary for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account owner and/or reseller providing you with the products and services (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our products and services and troubleshoot products and services; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and products and services, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the products and services; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.
International Data Transfers
Zoom operates globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected where Zoom or its service providers have customers or facilities – including in countries where meeting participants or account owners hosting meetings or webinars that you participate in or receiving messages that you send are based.
Therefore, by using ZCR Services or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States where we are established, as well as in other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.
We protect your personal data in accordance with this Privacy Statement wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws. Where personal data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission’s standard contractual clauses or other lawful mechanisms for transfers of personal data. Please contact us if you would like further information in that respect.
Zoom complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Zoom has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Zoom has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Statement and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Zoom commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Zoom at: privacy@zoom.us.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Zoom commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. Please contact us if you’d like us to direct you to your data protection authority contacts.
Zoom Communications, Inc., Zoom Voice Communications, Inc., and Solvvy, Inc., are adhering to the DPF Principles. The Federal Trade Commission has jurisdiction over Zoom’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).
If third-party agents process personal data on our behalf in a manner inconsistent with the DPF Principles, we remain liable unless we prove we are not responsible for the event giving rise to any damages. If you have a question or complaint related to our compliance with the DPF Principles, please contact us as indicated at the bottom of this privacy statement.
Under limited circumstances and after other available dispute resolution mechanisms have been exhausted, binding arbitration is available to address certain residual complaints under the DPF not resolved by other means.
California & Other U.S. States Notice at Collection
Categories of Personal Information Zoom Receives: Zoom may collect, or process on behalf of our customers, the following categories of personal data, as described above, in the “What Personal Data Do We Receive?”; section: identifiers (such as in Account Information, Profile and Participant Information, Contact Information, and Registration Information), financial account information (such as in Account Information); commercial information (such as in Account Information); internet or other electronic network activity information (such as Device Information, Usage Information Regarding Meetings, Webinars, Message, Collaborative Features, and the Website, and Limited Information from Zoom Email and Calendar Services); audio, electronic, and visual information (such as in Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features) education information such as from university customers; inferences we derive from the preceding or other information we collect; and sensitive personal information (such as certain categories in Account Information, Content and Context from Meetings, Webinars, Messaging, and Other Collaborative Features.
Sources: We receive information from sources as described in the “What Personal Data Do We Receive?”; section, including: from you (including through your use of our products and services); from partners (including data enrichment providers or data brokers); from customers; and from publicly available sources.
Zoom’s business and commercial purposes for use: Zoom uses personal data for the following business and commercial purposes: to provide Zoom Products and Services; for Product Research and Development; for Marketing and Promotions; Authentication, Integrity, Security, and Safety; to Communicate with You; and for Legal Purposes. For more information, please see “Data We Process & How We Use It.”; Categories of third parties to whom we disclose Personal Information for business purposes are described in “How Do We Share Personal Data?”;
Zoom may permit advertising and analytics services that are intended to deliver advertising to you and/or analyze your interactions, based on your interactions with our website or app which may constitute a “sale” or “sharing” of data for targeted advertising purposes under certain state privacy laws. See “California & Other U.S. State Privacy Rights” for more information regarding your right to opt-out.
Zoom may “sell” certain personal information, such as Business Contact Information, to help our ZCR Services customers identify and reach potential leads.
Retention: Zoom retains personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law. Additional detail on retention criteria can be found under Retention, above.
California & Other U.S. State Privacy Rights
Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have a right to:
- Access the categories and specific pieces of personal data Zoom has collected (such as Account Information, Business Contact Information, Device Information, Usage Information Regarding ZCR Services, Content from Third-Party Integrations, Communications with Zoom, and Information from Partners), the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Zoom has shared personal data (such as Resellers, ZCR Services customers, Vendors, Marketing, Advertising, and Analytics Partners, Corporate Affiliates, and Third-Party Developers), and obtain the personal data in a portable and, to the extent technically feasible, readily usable format;
- Delete personal data under certain circumstances;
- Correct personal data under certain circumstances; and
- Opt out of the “sale” of personal data. Zoom provides certain personal information, such as Business Contact Information, to help our ZCR Services customers identify and reach potential leads. Under the certain laws, making this information available to our ZCR Services customers may be considered a “sale” of personal information. To exercise your right to opt out of the sale of personal data through the ZCR data enrichment services, please click here. Zoom does not have knowledge that it has sold personal data of individuals under the age of 18 through ZCRA Services in the last year.
- Opt out of the “sharing” of personal data for targeted advertising purposes. Like many companies, we may use advertising and analytics services that are intended to analyze your interactions with our website or app, based on information obtained from cookies and similar technologies, including for delivering advertising to you (such as interest-based, targeted, or cross-context behavioral advertising). You can get more information and opt out of the use of cookies and similar technologies on our website and app by clicking the Cookies Settings or Your Privacy Choices, also on our homepage, and setting your preferences. You will need to set your preferences from each device and each web browser from which you wish to opt out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to re-select your preferred settings. Residents of California, Colorado, Connecticut, Montana, Nebraska, New Hampshire, and Texas may also set the Global Privacy Control (GPC) to opt out of the “sharing” of your personal information for targeted advertising for each participating browser system that you use. Zoom does not have actual knowledge that it “sells” or “shares” the personal information of consumers under 16 years of age.
- Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision. You can do so by replying directly to our denial or emailing privacy@zoom.us.
Zoom will not discriminate against you for exercising any of these rights, which is further in line with your rights under state law.
Sensitive Information. Zoom does not process information that may be considered sensitive under some state laws.
To exercise your rights, please click here or call +1-888-799-0566. To opt out of the use of cookies and similar technologies on our sites for interest-based advertising purposes, follow the instructions above.
We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to a total of 90 days) in writing.
These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency. To verify your identity, we may require you to log into your existing Zoom account (if applicable), give a declaration as to your identity under penalty of perjury, and/or provide additional information, such as providing at least two pieces of personal information relating to your account (which will be compared to information we have, such as profile information) or as we otherwise may already have in our possession, such as your email address and phone number. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.
To see our Disclosure of Privacy Rights Requests, please click here.
California’s Shine the Light Law
Under California’s Shine the Light law, you may also ask companies with whom you have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to privacy@zoom.us. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Changes to This Privacy Statement
We may update this Privacy Statement periodically to account for changes in our collection and/or processing of personal data, and will post the updated Privacy Statement on our website, with a “Last Updated” date at the top and an Update Note at the bottom. If we make material changes to this Privacy Statement, we will notify you and provide you an opportunity to review before you choose to continue using our products and services.
