1.  Scope and information that this Online Privacy Notice covers

This Online Privacy and Cookie Notice (this “Privacy Notice”) applies only to Personal Information (defined below) collected on our websites, mobile applications, or cloud-based services and communication platforms with a link to this Privacy Notice (collectively, the “Site”). This Privacy Notice includes information on how we collect, use, share, and otherwise process Personal Information since this Privacy Notice was posted. References to “Personal Information” in this Privacy Notice means information that identifies or can reasonably identify users of the Site (“you”) personally. 

Summary of Key Points

Collection

We generally collect Personal Information that you provide to us. Additionally, the computer systems used to operate the Website may acquire some of your Personal Information.

Use

We generally use Personal Information to collect anonymous statistical information on the use of the Website and to ensure it is working properly. The data collected is deleted immediately after processing. Further information about the use of your Personal Information in support of our business activities is available below.

Sharing

We only process and share your Personal Information to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives. Personal Information is accessible to our duly authorized personnel as necessary and is disclosed to third parties in the following cases: (i) when disclosure is required by laws and regulations applicable to legitimate third party recipients; and (ii) disclosure to third parties in the event of extraordinary transactions. Personal Information is also shared with our service providers. We provide such parties only with the data necessary to perform the agreed services. Further information about the use, processing, and disclosure of your Personal Information is available below.

Security

Our security measures include contractual arrangements with any contractor (e.g. service providers) or other party to protect the security and confidentiality of your Personal Information, prevent unauthorized access or disclosure of Personal Information in our custody or control, and maintain data accuracy in accordance with the provisions of our Privacy Policy.

Data Transfers Abroad

Your Personal Information may be transferred outside of your home country to third party recipients established within the EU, and to third party recipients and countries outside the EU, which may not guarantee the same level of data protection as the EU. If you are located in a jurisdiction that does not consider the outside country to provide an adequate level of protection, cross-border transfer of your information is necessary for the conclusion or performance of a transaction that you requested, and for the establishment, exercise, an defense of legal claims. However, you are advised that such transfer to third party countries will always be in accordance with the provisions of the Privacy Policy. Further information about the transfer of your Personal Information abroad is available below.

Data Retention

Depending on the program or service, we will retain your Personal Information only for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by a law or regulation that applies to us or the data retention for the program or service.

Children

Persons under the age of 16 are ineligible to use any services on our Site.

Changes

We may amend this Privacy and Cookie Policy at any time. If we make any material change in how we collect, use, disclose, or otherwise process Personal Information, we will prominently post an updated Privacy and Cookie Policy on our Website. 

Contact Us

Moncler USA Inc. can be contacted by writing to privacy@moncler.us

Industries S.p.A. can be contacted by writing to Industries S.p.A., via Stendhal n. 47, 20144 - Milan (MI), Italy or privacy@moncler.com or dpo@moncler.com. 

2.  CONTACT INFORMATION FOR DATA CONTROLLERS AND THEIR RESPECTIVE DATA PROTECTION OFFICERS

Moncler USA Inc. and Industries S.p.A., Moncler USA’s parent company act as independent data controllers.

As an independent data controller, Moncler USA Inc. will process your Personal Information in order to manage online sales activity (e.g. managing orders and payments), as well as for “pick-up in store”, “return in store”, “click from store” and “click and reserve” services.

·       Contact: Moncler USA Inc. can be contacted by writing to privacy@moncler.us

As an independent data controller, Industries S.p.A. will process your Personal Information in order to carry out marketing activities (e.g. newsletters) as well as profiling.

·       Contact: Industries S.p.A. can be contacted by writing to Industries S.p.A., via Stendhal n. 47, 20144 - Milan (MI), Italy or privacy@moncler.us or dpo@moncler.com.

3.  COLLECTION OF DATA AND THE PURPOSES OF DATA PROCESSING

Registration and other information provided

You are not required to create a personal account. For public areas of our Site, we generally collect and process only Personal Information you voluntarily provide to us. We don’t require you to give us Personal Information to access certain public areas of our Site. This is true unless you live in a jurisdiction that defines Personal Information to include network identifiers like your Internet Protocol addresses. For some secure areas of our Site, however, we require you to provide Personal Information, including your login credentials. We also collect your Personal Information on the Site to perform services on our Site, enhance the services we offer you, maintain and improve the Site, to secure you and our Site, comply with legal obligations, and inform you about other services and products that may be available through us, our affiliated companies, and our marketing partners.

If you choose not to provide us with the Personal Information that we legitimately require, we may be unable to provide you with the information or services you have requested. Public areas of our Sites ask for Personal Information from you when you engage in the following activities:

1. Register for an account with us;
2. Make a purchase on our Site;
3. Sign up for newsletters or general information about our programs and services;
4. Interact with us directly or through social networks;
5. Respond to surveys or submit comments, reviews, or other user-generated content;
6. Apply to join our team; and
7. Request customer or technical support.

Personal Information may include any or all of the following:

1.              First name and surname;

2.              Postal or billing address;

3.              E-mail address;

4.              Date of birth;

5.              Telephone or mobile number;

6.              Location via IP address;

7.              Device being used (for our mobile site);

8.              Previous login history and purchase history with our Site; and

9.              Other relevant data, including any information you provide when contacting us.

Even if you do not send us any Personal Information, we may collect certain non-personal information about how you use our Site. This non-personal information cannot reasonably identify you, and is used for statistical purposes.

Information Collected Through Technology

We may also obtain information in other ways through technology. Some of this information may be linked to you personally. We process this information to help our Sites function correctly, and better understand the needs of our customers.

Device Information. Depending on the permissions you’ve granted and other factors, we may receive information about your location and your mobile device, including a unique identifier for your device. Examples of the device information we collect include:

• Attributes such as the operating system, hardware version, device settings, battery and signal strength, and device identifiers.
• Certain device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals are gathered if you enabled the functionality within our product configuration.
• Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
• Gathering of IP address is used for our enhanced security.

Most mobile devices allow you to turn off location services, and we encourage you to contact your device manufacturer for detailed instructions on how to do that.

Purpose of the processing

We do not share your Personal Information with unaffiliated third parties solely for their own direct marketing purposes. We will not sell your Personal Information. Whatever the purpose may be – whether we share with service providers or other external entities – we only process and share your Personal Information to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives.

Providing the above registration information is necessary in order to create an account and also:

·       to respond to and manage questions, complaints, reviews of our services, requests for information, and/or user feedback;

·       to provide the services requested through the Website, including registration and subsequent updates and to manage the activities organized through the Website;

·       to carry out statistical analysis and surveys;

·       to manage sales activities; and

·       to provide sales and after-sales services, such as administration, accounting, returns and guarantee management, fraud prevention, customer relationship management, including compliance with legal obligations, regulations and EU regulations (including anti-money laundering regulations) and to exercise rights in legal proceedings

Any refusal by you to provide this information would still allow you to use the Website, but would prevent you from using some of our Services reserved for registered users.

In addition, your Personal Information must be processed in order to fulfill the contractual relationship arising from the purchase of Moncler products. You are free to disclose your data to us or not, but in the absence of the requested data you will not be able to purchase Moncler products and it will not be possible to handle your requests.

Further purposes of the processing

If we receive your consent, we will use your Personal Information for other purposes such as commercial or advertising communications, direct sales, in-store sales support worldwide through email (newsletter), telephone, SMS/MMS, or other marketing related communications. You may, at any time, indicate your preferred means of contact from among those listed above and you may refuse the receipt of promotional communication by any or all of these means of contact.

With your consent, which is optional, Moncler collects information about your preferences, habits and lifestyle as well as details of purchases made in order to use these to create group and individual profiles (“profiling”) and to send you personalized communications. Personalized communication may be sent by email (newsletter), phone, SMS, MMS, chat, instant messaging, social networking and traditional mail. You may at any time indicate your preferred means of contact from among those listed above and you may refuse the receipt of promotional communication by any or all of these means of contact.

Consent for the above marketing and profiling purposes is optional and refusal will not have any consequences. Data may be provided by you on registration at our points of sale by means of paper and/or electronic forms, acquired during visits to our stores belonging to the Moncler Group or through interaction with websites, internet applications and mobile applications belonging to the Moncler Group.

Legal grounds for the collection, use, sharing and other processing of Personal Information

Certain jurisdictions require the identification of the legal grounds for the collection, use, sharing, and other processing of Personal Information. We rely on the following legal grounds for the collection, use, sharing, and processing of Personal Information as described in this Privacy and Cookie Policy:

·       Necessary to provide information or otherwise carry out the performance of a contract with you as an individual;

• Our legitimate interests, including:
• Performance of the contract with you;
• Implementation and operation of a group-wide matrix structure and group-wide information sharing;
• Customer relationship management and other forms of marketing and analytics;
• Fraud prevention, misuse of company IT systems, or money laundering;
• Whistle-blower scheme operations;
• Physical, IT, and network perimeter security;
• Internal investigations; and
• Intended mergers and acquisitions;
• Compliance with legal obligations and/or defense against legal claims, including those in the areas of agriculture, energy, labor, social security, data protection, tax, and corporate compliance laws.
• Protection of the vital interests of any individual;
• Performance of a task carried out in the public interest or in the exercise of official authority vested in us; and
• Consent, as permitted by applicable law

Information collected through cookies and other technologies

Cookies are small files sent by websites that you visit and that are stored on the device you use to access those websites. When users visit the same site again, your browser reads the cookies stored on your device and sends the information back to the site that originally created the cookies. Our site also uses different types of cookies and other technologies to read and store information on the user’s device. We do not use cookies that are able to launch programs on your devices or send viruses to them, or that allow us to control your devices.

On the Website you may also find social buttons/widgets, in other words those distinctive “buttons” showing social network icons like Facebook, Instagram and Twitter. These buttons allow users who are browsing the Website to share and interact with social networks with a simple “click”.

Cookies for our Services generally fall into the following categories:

Technical Cookies: Technical cookies are necessary for the functioning of the Website, including the provision of the Services offered by the Website. This category of cookies includes analytics, session and functionality cookies, used by the owner to, for example, collect information, in aggregate form, about the number of users and how they use the Website or to save your browsing preferences, such as the language. This category of cookies does not require the users consent.

• Analytics Cookies: Analytics cookies are used to carry out statistical analyses by allowing us to recognize and count the number of users of our Website and see how those users navigate the Website. These cookies are collected anonymously and exclusively for statistical purposes. This helps to improve how our Website works, for example, by ensuring that users can find what they are looking for easily.

·       Our Own and Third Party Profiling Cookies: Our own and third party profiling cookies are designed to create user profiles and used to send and display advertising messages in line with the preferences expressed by users during their browsing. This category of cookies always requires the user’s optional consent.

The above cookies may be:

·       temporary, when they are automatically deleted at the end of the connection;

·       permanent, when they remain on the user’s hard drive, unless the user deletes them;

·       first party, when they are issued and managed directly by the Website administrator;

·       third party, when they are managed by a domain other than the one visited by the user.

While the use of technical cookies does not require the user’s consent, the use of profiling cookies always requires the user’s optional consent and the user can choose which profiling cookies to consent to. Cookies can be managed and disabled using the browser settings (e.g. Internet Explorer, Google Chrome, Safari, Firefox). Once on the site, the user will be able to access the “cookie selection” area and view the list of third party companies that place cookies on our site; check the presence and activity status of the installed cookie (“Status”) and selectively manage your consent (“On/Off”). Expanding the entry (Info) for each company will provide more information about the company and will link to the specific privacy and cookie policy.

4.  SECURITY

The security and confidentiality of your Personal Information matters to us. Our security measures include contractual arrangements with any contractor (e.g. service providers) or other party in order to protect the security and confidentiality of your Personal Information, prevent unauthorized access or disclosure of Personal Information in our custody or control, and maintain data accuracy in accordance with the provisions of our Privacy Policy.

5.  METHODS OF DATA PROCESSING AND DATA STORAGE

Your Personal Information will be processed both in paper form and using electronic means and always in compliance with the security requirements of applicable legislation. Personal Information

Your Personal Information is stored in compliance with the following terms and criteria:

1.     Data collected to conclude and execute agreements for the purchase of products on the Website: until the administrative and accounting formalities have been completed. Billing information will be retained for ten years from the date of the original invoice;

2.     Registered user data: this data will be stored for as long as the account is active. Even after the account is closed, we will retain your information if it is necessary to do so in order to comply with legal or regulatory obligations, to protect our rights, to prevent fraud, or to comply with this Privacy Policy;

3.     Data relating to payment: until such time as the payment has been confirmed and the administrative and accounting formalities relating thereto have been completed, after the expiry of the right of withdrawal and after the deadline for contesting the payment;

4.     Data collected in connection with the use of Services offered on the Website (e.g. “pick-up in store”, “return in store”, “click from store”, “click and reserve”): such data is stored until the service has been fully performed;

5.     Data related to user requests to our Client Service department: relevant data will be retained until your request is resolved;

6.     If you have consented to your Personal Information being processed, the data relating to your purchases will be kept for marketing and profiling purposes for a period of seven (7) years, after which time the data will be automatically deleted or permanently and irreversibly anonymized.

In any case, for technical reasons, the termination of the processing and the subsequent cancellation or irreversible anonymization of the related Personal Information will be final within thirty (30) days of the terms indicated above.

6.  SCOPE OF DISCLOSURE

Internal and external communication of Personal Information

Sale of the Businesses. If we sell all or part of our business, Personal Information may be transferred to the purchaser in connection with that transaction. We will use reasonable efforts to include contractual provisions that require the purchaser to treat your Personal Information consistent with the terms of this Privacy Notice.

Other Disclosures. We may otherwise disclose Personal Information as permitted or required by law, when we believe in good faith it is necessary for safety purposes, required for legal reporting, or to protect our legal rights or enforce our Site’s terms and conditions or any applicable rules, or to protect the rights of others. We may also disclose Personal Information to our auditors, legal advisors, or to respond to a subpoena. We may also aggregate information that we gather about you (e.g., online sales, traffic patterns) and provide these statistics to others in aggregate form.

Any access to your Personal Information is restricted to those individuals who have a need to receive or access this data in order to fulfill their job responsibilities. We may also disclose your Personal Information as required or permitted by applicable law to governmental authorities, courts, external advisors, and similar third parties.

Finally, for the purposes of profiling, marketing and customer relationship management (to provide you with the same level of service worldwide), other companies in the Moncler Group may access your Personal Information as data processors, based on instructions received from Moncler.

Data transfer abroad

Your Personal Information may be transferred outside of your home country to third party recipients established within the EU, and to third party countries, not belonging to the EU, which do not guarantee the same level of data protection as the EU. If you are located in a jurisdiction that does not consider the outside country to provide an adequate level of protection as the EU, cross-border transfer of your information is necessary for the conclusion or performance of a transaction that you requested, and for the establishment, exercise, an defense of legal claims. However, you are advised that such transfer to third party countries will always be in accordance with the provisions of the Privacy Policy, i.e. by obtaining your consent, when necessary, or by adopting any other measure necessary to ensure the security of the data being transferred. To the extent permitted by local law, your use of this Website or provision of any Personal Information constitutes, where legally permitted, your consent to the cross-border transfer of Personal Information and other activities identified in this Privacy and Cookie Policy.

7.  RIGHTS OF THE DATA SUBJECT

As a data subject, you may at any time exercise the rights under applicable Privacy Legislation and as acknowledged by the Privacy Policy with regard to the specific processing of your Personal Information. Please note that these rights might be limited under the applicable national data protection law.

Below is a general description of them and how to exercise them:

1. Right of access: You may have the right to obtain from us confirmation as to whether or not Personal Information concerning you is processed, and, to request access to the Personal Information. The access information includes, among other things, the purposes of the processing, the categories of Personal Information concerned, and the recipients or categories of recipient to whom the Personal Information have been or will be disclosed. This is not, however, an absolute right, and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of their Personal Information undergoing processing.
2. Right to rectification: You may have the right to obtain from us the rectification of inaccurate Personal Information about you. Depending on the purposes of the processing, you may have the right to have incomplete Personal Information completed, including by means of providing a supplementary statement.
3. Right to erasure: Under certain circumstances, you may have the right to obtain from us the erasure of Personal Information concerning you, and we may be obligated to erase that Personal Information, as long as it is not required for legal or regulatory purposes.
4. Right to restriction of processing: Under certain circumstances, you may have the right to obtain from us restriction of processing your Personal Information. In that case, your data will be marked and may only be processed by us for certain limited purposes. As we process and use your Personal Information primarily for purposes of carrying out the contract for services and in furtherance of our relationship, we have a legitimate interest for the processing which may override your restriction request, unless the restriction request relates to marketing activities.
5. Right to data portability: Under certain circumstances, you may have the right to receive the Personal Information about you, which you have provided to us, in a structured, commonly used and machine-readable format, and you may have the right to transmit that data to another entity without hindrance from us.
6. Right to object: Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your Personal Information by us, and we can be required to no longer process your Personal Information.
7. Financial incentives: you may have the right to be notified of any financial incentives offered to you in exchange for any right we wish to have to collect, sell or delete your Personal Information.

8.        INFORMATION FOR US RESIDENTS: CALIFORNIA AND COLORADO

Under the California Consumer Privacy Act ("CCPA"), as amended by the Consumer Privacy Rights Act (“CPRA”) (collectively, "California Privacy Law") and the Colorado Privacy Act (“CPA”), (collectively, “US Privacy Law”), we provide specific disclosures about how we use and disclose your information. If you are a California or Colorado resident, please note the following about how we have collected, used, disclosed and otherwise processed your personal information over the past 12 months, as well as additional rights you may have with respect to your personal information. This Notice does not reflect our processing of California or Colorado residents' personal information where an exception under California or Colorado law applies.

Personal Information. Consistent with the "Collection of Data and the Purposes of Data Processing" section above, we may collect certain categories of information ("Personal Information") about California and Colorado residents, such as:

• Identifiers: real name, address, email address, telephone or mobile number, other contact information, information collected via Cookies;
• Commercial Information: transaction history, demographic information;
• Internet or network activity information: browser, operating system, browsing history and interactions with our website;
• Geolocation Data: precise location of your mobile device or images uploaded from your mobile device;
• Audio, visual, and similar information: we may record your calls to our support team with your permission;
• Inferences: drawn from any of the Personal Information listed above to create a profile about an individual's preferences and characteristics, for example;
• Other information: including any information you provide when contacting us.

Certain Personal Information that we collect about you may be considered Sensitive Personal Information within the meaning of US Privacy Law, including: precise geolocation information (for providing services). We only use and disclose Sensitive Personal Information as necessary in connection with the performance of services and the provision of goods, compliance with federal, state, or local laws, and as otherwise permitted by US Privacy Law.

Sources of Personal Information. Consistent with the "Collection of Data and the Purposes of Data Processing" section above, we may collect Personal Information from you when you interact with our Site.

Uses and Disclosures of Personal Information. We use and disclose Personal Information as described in the "Purpose of Processing," "Further Purposes of Processing" and “Scope of Disclosure” sections above.

Disclosures to Third-Parties.

·       Disclosure of Personal Information for Business Purposes. We disclose the following categories of personal data for business purposes: Identifiers, Commercial Information, Internet or Other Electronic Network Activity, Geolocation Data, Audio Information, and Other Information to web hosting, payment processing, business analytics, customer service, and business partners.

·       Disclosure of Personal Information for Commercial Purposes. We disclose the following categories of personal data for commercial purposes: Identifiers, specifically, preferences and interests on our Site, collected via Cookies to advertising technology providers and, in limited instances, email addresses in hashed format, to social media companies, marketing, and survey service providers. These are sharing activities that may be considered a sale under California Privacy Law or targeted advertising under the CPA.

Right to Opt-out of Sale, Sharing, or Targeted Advertising. In addition to the rights stated below, California and Colorado residents have the right to opt-out of the selling, sharing, or targeted advertising of their Personal Information, as such terms are defined under US Privacy Law. To exercise this right, please click here [https://www.moncler.com/en-us/client-service/contact/]. In addition, we have configured our cookie management tool to honor opt-out preference signals sent by Global Privacy Control ("GPC") within the browser. Please note that due to technical limitations, the GPC signal is only honored within the particular browser. Beyond GPC, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different Web sites or digital apps following your visit to one of our Sites.  

Data Retention. We keep your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with you; (ii) as required by a legal obligation to which we are subject to; or (iii) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).We may remove Personal Information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, we may delete Personal Information from our database at any time and without providing any reason.

US Privacy Law Rights. You may have the right to access, correct or delete your Personal Information, subject to certain exceptions. Specifically, you have the right to request:

1.     Deletion of your Personal Information;

2.     Correction of your inaccurate Personal Information;

3.     Know/access the categories of Personal Information that we collected about you, including the specific pieces of Personal Information;

4.     Categories of Personal Information disclosed for a business purpose; and

5.     Specific to California residents, information about the categories of Personal Information about you that we have shared (as such term is defined under California Privacy Law) and the categories of third parties to whom the Personal Information was shared.

In some instances, we may decline to honor your request. For example, we may decline to honor your request if we cannot verify your identity or confirm that the Personal Information that we maintain relates to you. In other instances, we may decline to honor your request where an exception under US Privacy Law applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer.

If you are a California or Colorado resident, to make a request described above relating to Personal Information that we collected about you that is not subject to an exception under US Privacy Law, you may:

• call the toll-free number +1(888)320-9162 from Monday to Friday from 10 a.m. to 7 p.m., excluding public holidays;

• online, here [https://www.moncler.com/en-us/client-service/contact/] by selecting the “privacy” topic in the relevant form in the “Contact us” section of the Website;

• contact Moncler USA Inc. and Moncler directly at the addresses indicated in Section 2 above.

Authorized representative. You can designate an authorized agent to make a request under US Privacy Law on your behalf in certain circumstances. If you use an authorized agent for this purpose, we may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request on your behalf. In California, if you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with California law.

You will not be penalized for exercising your rights to your Personal Information. And, if we deny your request, we will explain why.

Shine the Light Law.  California residents are entitled once per year to request and obtain certain information regarding our disclosure, if any, of your personally identifiable information to third parties for their direct marketing purposes during the immediately prior calendar year. To make such a request, please send an email to privacy@moncler.us with your full name, email address, and postal address in your message. In response to your request, we will provide you with a notice describing the cost-free means to opt-out of our sharing your personally identifiable information with third parties with whom we do not share the same brand name, if the third party will use it for their direct marketing purposes.

Do-not-track (“DNT“) signals sent via browsers

Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we generally do not respond to DNT signals at this time.

9.  CHILDREN

We do not knowingly collect Personal Information from children under the age of 16. If a child under the age of 16 has provided us with Personal Information, we ask that a parent or guardian contact us at the contact details provided above.

10. COMPLAINTS

If you believe that your Personal Information has not been correctly processed, you may contact us using the contact information noted in Section 2 above. For Colorado residents, you may appeal a decision we make regarding a rights request by emailing us at [EMAIL ADDRESS].

You also have the right to lodge a complaint with a competent data protection supervisory authority. To exercise your rights, please contact us as set out below.

·       call the toll-free number +1(888)320-9162 from Monday to Friday from 10 a.m. to 7 p.m., excluding public holidays;

·       write to Client Service by selecting the “privacy” topic in the relevant form in the “Contact us” section of the Website; or

·       contact Moncler USA Inc. and Moncler directly at the addresses indicated in Section 2 above.

11. CHANGES OR OTHER UPDATES TO THIS PRIVACY AND COOKIE POLICY

We may amend this Privacy and Cookie Policy at any time. If we make any material change in how we collect, use, disclose, or otherwise process Personal Information, we will prominently post an updated Privacy and Cookie Policy on our Website. Any changes to this Privacy and Cookie Policy will be effective immediately upon posting of the updated Privacy and Cookie Policy or as otherwise required by applicable law. Where required to do so by law, we will seek your prior consent to any material changes we make to this Privacy and Cookie Policy.