Privacy Policy

Effective Date: October 1st, 2024

ImGn Labs II and its affiliates (“BERO,” “we,” “us” or “our”) recognizes the importance of protecting the privacy of our customers and online visitors. The following privacy policy (“Privacy Policy”) describes the processing of personal information that is provided, collected, or disclosed while providing our products or services to you, and on the websites, applications, and online platforms that link to this Privacy Policy (collectively, “Site”), including when you apply for a job with us. 

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY to understand our policies and practices regarding your personal information and how we treat it.

Information We Collect

Personal Information 

BERO collects personal information from you, which may include:

• Name
• Address
• Email address
• Password for your account login with us
• Telephone number
• Whether you are older than 21 years old
• Payment information (e.g., credit card number, billing address, card expiration date, security code)
• Details of your specific orders and transactions with us, including the products you’ve purchased and your shopping/consuming histories 
• Geolocation through your IP address
• Your marketing preferences
• The information you provide, including any messages, to send our products as gifts to another individual
• If you would like to be a retailer or wholesaler of our products, the name of your business and your business’ website
• If you would like to be a BERO ambassador, your social media account URL (e.g., your Instagram or TikTok account URL), your favorite BERO product and reasons as to why you should be a BERO ambassador
• If you post a photograph on social media and tag us or if you post a comment on our social media pages, we will collect the photograph or content of that message. Please note that if you choose to post photograph on social media and tag us or post a comment on any of our social media pages, any information you post will be visible to any other visitors to that social media page. We are not responsible for any personal information you include in such posts or for any use of such information by any other visitor to the social media page.
• Any information you may provide to us when you contact us or engage with the chat functionality on the Site
• Any information you upload or post to the Site, including any reviews.

This information is collected and stored electronically when you purchase our products, register an account with us, join our loyalty programs or membership, subscribe to our email list or sign up to receive text messages from us, apply to become one of our retailers or wholesalers or a BERO ambassador, engage with the Site’s chat functionality or otherwise contact us. We may also collect your personal information when you respond to our surveys and questionnaires or join our interest list through the links provided by our celebrity ambassadors. 

Where permitted by applicable law, we may combine your personal information with other information we have collected from you. We may also combine your personal information with information we receive about you from other sources, such as our service providers.

Cookies and Other Tracking Technologies

We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Site. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Site, to enhance your experience through personalization, and to help us better understand the features of our Site that you and other users are most interested in. 

Website Delivery and Appearance – We may use third-party providers to enable certain customer interaction opportunities, content delivery, or other service capabilities. Examples include, but are not limited to, the following functionality:

• Chat-based Customer Support: We use an interactive chat feature powered by a third-party, which may utilize artificial intelligence, to enable customer service and technical support via our Site. When you engage in the chat enabled by this service provider, you may be interacting with an automated and artificial system, not a human representative. Additionally, to provide the customer service and technical support enabled by this interactive system, we will automatically collect and share certain information (such as personal identifiers, usage information, and message content) with the supporting vendor. Any personal information disclosed with that third party via this interactive tool will be handled in accordance with the applicable third party’s privacy policy. Please see their individual policy and terms to learn more.
  

Website Analytics and Session Replay – We use analytics and session replay services, that use cookies and other technologies that collect your personal information, to assist us with analyzing our Site traffic and site usage to optimize, maintain, and secure our Site and inform subsequent business decisions (including, e.g., advertising). These include, but are not limited to, the following third-party services: 

• Microsoft Clarity: We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our Site through behavioral metrics, heatmaps, and session replay to improve and market our products and services. Site usage data is captured using cookies and other tracking technologies to determine the popularity of products, services and online activity. Additionally, we use this information for Site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
• Google Analytics: To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data from sites or apps that use our services.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
• Pixels: We use Meta and TikTok pixels to track user activity on our Site and improve downstream offerings, including interest-based advertising for our services and those of our partners and service providers.
  

Interest Based Advertising

We may collect information about your online activities on our Site to provide you with advertising about products tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our advertisements are served. 

You may see certain advertisements on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites, including our Site, by collecting information through automated means, including through the use of third-party cookies, pixels, web server logs and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our advertising partners’ targeted advertising services to show you our advertisements on other websites based on your prior visits to our Site and other online activity.  Examples of the third-party service providers we engage to serve interest-based advertisements include Google Ads (including Google Dynamic Remarketing and Google Signals), Meta Ads (including Meta Pixels and Facebook advertising services), and Microsoft Advertising. 

While we do not sell Personal Information in exchange for monetary consideration, we do disclose personal information for other benefits that could be deemed a “sale” under various data protection laws because it is sometimes broadly defined to include activities such as the delivery of interest-based advertising on websites or allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior.

To manage your preferences with respect to cookies and other tracking technologies, you can:

• Change your cookie preferences by clicking “Manage Preferences”  or customizing your browser settings to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable certain cookies, please note that some parts of our Site may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.
• Block the collection and use of your information by online platforms and ad tech companies for the purpose of serving interest-based advertising by visiting the opt out pages of the self-regulatory programs of which those companies are members: National Advertising Initiative and Digital Advertising Alliance (or the European Interactive Digital Advertising Alliance, if you are located in the European Economic Area). Please note that even if you opt out of interest-based advertising, you may still see “contextual” ads which are based on the context of what you are looking at on the websites and pages you visit.
• Review and execute any provider-specific instructions to customize your preferences or opt-out of certain processing, including interest-based advertising, by third-party service providers. For example, to opt-out of this type of advertising by Google, customize your ad preferences, or limit Google’s collection or use of your data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. 
  

How Information is Used 

We may use the information we collect for any of the following purposes:

• To provide our products, services, and/or the Site to you;
• To verify that you are at least 21 years old;
• To fulfill your requests, such as those related to ordering and payment; 
• To create and manage your account with us;
• To administer our loyalty program and membership;
• To enable you to become a retailer or wholesaler of our products or a BERO ambassador;
• To operate and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
• Personalize our advertising, marketing communications, shopping experiences and promotional offers and to deliver promotions and offers to you that we think may be of interest to you;
• If you join our interest list or sign up for our email list or to receive promotional text messages, to send you emails or text messages about products or offers that we think might be of interest to you;
• For customer service, security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
• For research and analytics purposes; 
• To respond to your inquiries and communicate with you, including without limitation via the Site’s chat functionality;
• To send you surveys and/or questionnaire regarding your satisfaction with our services, products and overall experience in connection with BERO;
• For our other business purposes, such as data analytics, audits, developing new products, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our promotional campaigns;
• As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Use; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

Email marketing (if applicable): Where we have a legal basis, we may send emails about our store, new products, and other updates (see our “Marketing Preferences” section for more information).

Text marketing (if applicable): We may send text messages about our store, new products, and other updates. Updates include Checkout Reminders. The website uses webhooks and cookies (with your consent) to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS (see our “Marketing Preferences” section for more information).

Marketing Preferences

We would like to send you information about products and services of ours that we think you might like. We may send you direct marketing communications, product information and promotional offers:

• If you have consented to receiving such communications from us
• If we have an existing business relationship with you and can rely on your implied consent
• If you are from a country where the laws permit us to send you such communications based on our legitimate interests, if you have bought a product or service from us, and have not opted out of receiving communications from us (for example the EEA or UK)
• If you are from a country where the laws permit us to send you such communications

The marketing communications we send will be in relation to our own products or services, your personal information will not be used for third-party direct marketing unless separate explicit consent has been collected for that or you are from a country where the laws permit such processing.

You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us at any time:

• You can unsubscribe by using the unsubscribe directions or link included in marketing communication from us; or
• You may withdraw your consent by contacting us by e-mail at support@berobrewing.com

Customers located in certain regions, such as the EEA and UK, also have the right to object to their personal information being processed for direct marketing purposes at any time. If you would like to object you can contact us by e-mail at support@berobrewing.com

We will process all requests as soon as possible, but please note that due to the nature of our IT systems and servers it may take a few days for any opt-out request to be implemented.

Disclosure of Information 

We may disclose your information:

• With Third Party Service Providers Performing Services on Our Behalf. We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site, provide data analytics and research on the Site, send out emails and text messages about the Site and our products, provide the chat functionality on the Site, provide our surveys and questionnaires, process payments, ship our products to you, provide customer support.
• With our Affiliates and Business Partners. We may share your information with affiliates for our internal business purposes and our business partners to enhance our offerings or promotions.
• Through Tracking Technologies. We may share information collected through tracking technologies set on the Site with our website analytics and digital advertising service providers. When we share your personal information in this context, we follow applicable legal requirements, which may require that we provide opt-out rights or other individual rights.
• For Legal Purposes. We also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain. 
• Changes of Control. We may transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. 

BERO does not share your personal information with third parties for those third parties’ direct marketing purposes.

Links to External Websites and Online Services

Our Site may contain links to third-party websites and online services. Any access to and use of such third-party websites or online services is not governed by this Privacy Policy, but is instead governed by the privacy policies of those third-party websites or online services, and we are not responsible for the information practices of such third-party websites or online services.

Social Media

Some aspects of the Site may allow you to interface with social media, such as Instagram and TikTok. We will attempt to identify these aspects of the Site to you, for example, by identifying them with the applicable third-party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services. If you interface with our social media pages through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services. For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

Consent to Receive Communications

You may decide to subscribe to one of our short code mobile message programs (the “Program”) to receive SMS/text messages from BERO. If you choose to opt-in and consent, such as by providing your telephone number to us and clicking submit online, we will collect information about your interactions with the SMS/text messages that we may send to you from time to time as part of the Program(s) in which you are enrolled.

By providing your telephone number and clicking submit online, you agree to this Privacy Policy, and authorize us to make or initiate sales calls, text messages and prerecorded voicemails to that phone number using an automated system. Your agreement is not a condition of purchasing any products, goods or services. Message & data rates may apply, and message frequency may vary.

BERO does not sell information that we obtain from you through our Program, including personal information you submit to us online to consent and opt-in to the Program, and we do not share that information with non-affiliated third parties for any purpose other than to provide the services, and other information requested by you, or to fulfill our legal obligations.

Your Rights and Choices

You may choose to stop receiving our marketing emails and text messages by following the unsubscribe instructions included in such emails and text messages, updating your communications preferences in your membership account on the Site or contacting us at support@berobrewing.com.

You may also manage the sharing of certain personal information with us when you connect with us through your social media account. Please refer to the privacy settings of your social media account to determine how you may adjust our permissions and manage the interactivity between the Site and your social media account.

You may change any of your personal information in your account by editing your profile within your account or contacting us at support@berobrewing.com.

International Use and Cross-Border Data Transfers

If you are visiting our Site from outside of the United States, please note that our Site is hosted in the United States. Where permitted by applicable law, we may transfer the personal information we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Privacy Policy. 

For individuals in the European Union, European Economic Area, Switzerland, and United Kingdom: BERO will only transfer personal information third parties located outside of this region when it has ensured appropriate safeguards for such personal information through use of the standard contractual clauses or other lawful and approved methods. To request a copy of applicable cross-border data transfer agreements, please reach out using the information in the Questions / Contact Us section.

Security & Retention of Personal Information 

BERO uses reasonable security measures designed to prevent unauthorized intrusion to the Site and the alteration, acquisition or misuse of personal information. However, please note that no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. It is your responsibility to protect the security of your login information. 

We retain your personal information for as long as needed: (i) to conduct business with you; (ii) fulfill the purposes outlined in this Privacy Policy; and (iii) to comply with our legal obligations, resolve disputes, and enforce any agreements. Criteria we will use to determine how long to retain your personal information include the nature and length of our relationship with you; our legal rights, obligations, and retention requirements; and if we have an ongoing business purpose for retaining your personal information. 

Children 

We do not knowingly collect or maintain personal information from any person under the age of 21. No parts of our Site are directed to or designed to attract anyone under the age of 21. 

Exercising Your Privacy Rights

Depending on where you live, you may have the following rights with respect to your personal information under applicable data protection laws:

• Access – The right to request access to and obtain a copy of any personal information we may have about you.
• Deletion – The right to delete your personal information that we have collected or obtained, subject to certain exceptions.
• Correction – The right to request that we correct any inaccuracies in your personal information, subject to certain exceptions.
• Opt Out of Certain Processing – The right to: (a) opt out of the processing of your personal information for purposes of targeted or cross-context behavioral advertising, (b) opt out of the sale of your personal information, and (c) limit the use of your sensitive Personal Information (if applicable). We do not collect or process sensitive Personal Information outside of purposes permitted by law (such as section 7027(m) under the California Consumer Privacy Act Regulations), so we do not offer the option to limit its use.
• Objection/Restriction of Processing – The right to object or restrict us from processing your personal information in certain circumstances.
• Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your personal information.
• Automated Decision-Making – The right to know when you are subject to automated decision-making, the personal information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right, depending on your location, to consent or opt out of (a) this automated decision-making or (b) any profiling in furtherance of decisions that produce legal or similarly significant effects. We do not profile you or other individuals in a manner that would result in legal or similarly significant effects, or engage in automated decision-making, so we do not offer an opt out of such activity.
• Lodge a Complaint – The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.
  

You may exercise these rights by contacting us at support@berobrewing.com. You may also exercise your opt out rights by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC). We honor Opt-Out Preference Signals, including GPC. If you choose to use an Opt-Out Preference Signal, you will need to turn it on for each supported browser or browser extension you use.

You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Notice. However, should you withdraw your consent or object to processing of your personal information, or if you choose not to provide certain personal information, we may be unable to provide some, or all, of our products or services to you.

Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your personal information. We may need to verify your identity before fulfilling certain requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making certain requests on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of power of attorney. We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.

EU/UK/Switzerland Residents

With respect to “personal data” as defined by Regulation (EU) 2016/679 (“GDPR”), any national law of an EU member state adopted pursuant to the GDPR, the UK Data Protection Act of 2018, and the Switzerland Federal Act on Data Protection (collectively, “European Data Protection Laws”), we serve as the “controller”.

The categories of personal information we process about you is set forth in Section 1 (Information We Collect). The purposes for processing such personal information are set forth in Section 3 (How Information is Used). We disclose the personal information we process about you with the third parties set forth in Section 4 (Disclosure of Information).

Our legal bases for processing your personal data are as follows:

• Performance of Contract. We may use your information to perform our contractual services or prior to entering into an agreement with you. If you use the Site or if you purchase our products, we use your information to provide to you the features and functionality of the Site and our products, including for customer service. 
• Legitimate Interest. We may use information for our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms. For instance, we may use your personal data to contact you and respond to your requests and inquiries, to administer our business including by creating statistical analyses, to identify prevent and detect fraud or to pursue or defend ourselves against legal claims.
• Consent. We may use your information with your consent. In these instances, we will ask you to grant us consent to use your information. You are free to grant or deny permission. If you deny permission, we will not be able to process your information to conduct the activity to which the consent relates. For example, we will not be able to send you marketing materials that you request. You are also free to withdraw your consent at any time. A withdrawal of consent will not affect processing that has been completed during the time in which the consent was valid. If you have granted us consent to use your information, we will use it only for the purposes specified when we request your consent. This includes use for our marketing campaigns. If you sign up for our newsletter or to receive text messages from us, you allow us to use your email address or telephone number for marketing related to the Site and our products. We will use your personal data to send you emails or text messages containing newsletters, promotions and special offers. You may unsubscribe from such emails or text messages at any time by following the unsubscribe instructions in such messages, updating your communications preferences in your membership account on the Site or contacting us at support@berobrewing.com 
• Fulfillment of Legal Obligation. We may use your information to comply with our legal obligations. To comply with regulations, laws or any authority requests, we may disclose your information to authorities or other officials or otherwise process your information pursuant to legal obligations we are subject to (e.g., retain certain information according to tax or commercial laws, respond to your requests to exercise your rights under European Data Protection Laws).

We only collect “Special Category Data” where we have a lawful basis for doing so that is permitted under European Data Protection Laws, specifically within the employment context. If you apply for a job with us, we may collect data that reveals your racial or ethnic origin, trade union membership, sexual orientation, or health to fulfill our obligations, exercise our rights, and otherwise administer our employment relationship with you (including initial recruitment and hiring, where applicable). For example, we may collect health information to make reasonable disability accommodations; immigration information to verify your right to work in a particular jurisdiction; and data points like your race, ethnicity, and sexual orientation to monitor equal opportunities. Please refrain from sending us any Special Category Data outside this employment context.

California Residents

This section provides additional information regarding BERO’s practices pursuant to the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (“CCPA”), where “Personal Information” has the definition set forth in the CCPA.
Please see the chart below for detailed information about the categories of Personal Information we have collected from California residents during the twelve months preceding the date on which this Notice was last updated and the categories of third parties to whom we Sell or Share Personal Information (as those terms are defined in the CCPA). For each category of Personal Information set forth in the chart below, the categories of third parties to whom we disclose it for a business or commercial purpose are set forth in the Disclosure of Information section above. 

Personal Information Category set forth in Cal. Civ. Code § 1798.140	Categories of Third Parties to Whom We Sell or Share Personal Information
Personal identifiers, including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.	Third-party marketers and other third parties that set cookies and other online tracking technologies on our Site.
California Customer Records Personal Information (Cal. Civ. Code § 1798.80(e)), including name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, etc.	We do not Sell or Share this category of Personal Information.
Characteristics of protected classifications under California or federal law. This may include age, veteran status, accommodations information, gender identity and expression, sexual orientation, and religion.	We do not Sell or Share this category of Personal Information.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.
Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement.	Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.
Geolocation data, such as your IP address.	Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.
Sensory data including audio, electronic, visual, thermal, olfactory, or similar information.	We do not Sell or Share this category of Personal Information.
Professional or employment-related information.	Third-party marketers, analytics providers and other third parties that set cookies and other online tracking technologies on our Site.
Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99)	We do not Sell or Share this category of Personal Information.
Inferences drawn from any of the information categories to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	We do not Sell or Share this category of Personal Information.
Sensitive Personal Information as set forth in Cal. Civ. Code § 1798.140, including social security number, driver’s license number, state identification card, or passport number; citizenship or immigration information; racial or ethnic origin; account access credentials (like usernames or account numbers combined with password or other security/access code to access an account).	We do not Sell or Share this category of Personal Information.

 

California Shine the Light – Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us at support@berobrewing.com. Please be aware that not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

Questions / Contact Us

If you have any questions regarding this Privacy Policy, please contact us at support@berobrewing.com. 

Changes to this Privacy Policy

Please note that we may modify or update this Privacy Policy from time to time, so please review it periodically. If we make material changes to how we treat personal information, we will notify you according to applicable law. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to our Site. You are responsible for periodically visiting our Site and this Privacy Policy to check for any changes.