Status: 24 May 2018

Data Protection and Privacy Statement

We, TER HELL & Co. GmbH, Börsenbrücke 2, 20457 Hamburg, are glad you've chosen to visit our website. Protecting your privacy is a high priority for us. We take the protection of your personal data very seriously, and comply strictly with the rules of data protection laws. On this website, personal data is only collected to the extent it is technologically required. Below, we will inform you about the type, scope, and purpose for collecting, processing, and using your personal data in connection with your use of our website.

Information about the collection and processing of your personal data

Care and transparency is the foundation of trustful collaboration with our customers and suppliers. This is why we will inform you about how we process your data and how you can exercise the rights that are due to you pursuant to the EU General Data Protection Regulation (GDPR). What personal data we process and for what purpose depends on the respective contractual relationship.

1 WHO IS RESPONSIBLE FOR DATA PROCESSING?

The controller is:

Company: TER HELL & Co. GmbH

Address: Börsenbrücke 2, 20457 Hamburg

represented by the Managing Director: Christian Westphal

2 HOW CAN YOU CONTACT THE DATA PROTECTION OFFICER?

You can contact our Data Protection Officer under:

Dr. Klaus zu Hoene
Data Protection Officer
intersoft consulting services AG
Beim Strohhause 17
20097 Hamburg
data.protection[at]tergroup.com

3 WHAT PART OF YOUR PERSONAL DATA DO WE USE?

We process personal data that we receive from our customers, suppliers, or other affected parties in the course of our business relationships. We also process – inasmuch as it is necessary for our business relationships – personal data that we receive from publicly available sources in a permissible manner or that is legitimately disclosed to us by other companies of the TER Group or by other third parties. We also process your personal data for reasons including the fulfillment of legal obligations, to protect a legitimate interest, or on the basis of consent that you have given.

According to the legal basis, this concerns the following categories of personal data:

  • First name, last name
  • Address
  • Communication data (telephone number, email address)
  • Date of birth
  • Citizenship
  • Master data of the contract, in particular the contract number, term, notice period for termination, type of contract
  • Invoice information/sales information
  • Information about creditworthiness
  • Payment information/contact information
  • Account information, in particular the registration and log-ins
  • Videos or images
  • Applications, resume, certificates and evidences of formal qualifications

In the course of contract initiation, we also use data that has been provided to us by third parties. According to the type of contract, this concerns the following categories of personal data:

  • Information about creditworthiness (via credit agencies/credit insurers)

4 WHAT IS THE SOURCE OF THE DATA?

We process personal data that we receive from our customers, suppliers, or applicants in the course of our business relationships.

We also receive personal data from the following sources:

  • Credit agencies
  • Internet and media
  • Publicly available sources: commercial registers or registers of associations, records of debtors, land registers
  • Other Group companies
  • Job portals

Our websites may contain links to other websites or services that do not belong to us and are not controlled by us. This Data Protection and Privacy Statement only applies to information that is collected from our website.

5 FOR WHAT PURPOSE ARE WE PROCESSING YOUR DATA, AND WHAT IS THE LEGAL BASIS?

We process your personal data particularly under observation of the EU General Data Protection Regulation (GDPR), as well as of all other relevant laws.

5.1 ON THE BASIS OF CONSENT THAT YOU HAVE GIVEN (ART. 6 PARA. 1 A GDPR)

If you have given us your free consent to collect, process, or transfer certain personal data, this consent remains the legal basis for the processing of this data.

In the following cases, we process your personal data on the basis of your consent:

  • Contact forms: Personal data is recorded by us if you voluntarily share it with us , such as if you contact us. When we ask for entries that are not necessary to contact you on our contact form, we have marked them as optional. This information helps us to add detail to your inquiry and improves our ability to carry out your request. A communication of this information explicitly occurs on a voluntary basis and with your consent. If this concerns information about communication channels (such as email address, telephone number), you also consent to having us contact you using these communication channels to answer your request.
  • Sending an email newsletter
  • Personalized newsletter tracking
  • Market research (e.g. customer satisfaction surveys)
  • Marketing and advertisement development using customer profiles
  • Publication of a customer reference (name and image)
  • Storage of your application data beyond 6 months
  • Use of functional-, analytical- or marketing cookies as follows:

5.1.1. Google Analytics

If you have given your consent, this website uses Google Analytics, a web analysis service of Google LLC. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

 

Scope of processing

Google Analytics uses cookies that enable an analysis of your use of our website. The information collected by the cookies about your use of this website is usually transferred to a Google server in the USA and stored.

We use the function 'anonymizeIP' (so-called IP-Masking): Due to the activation of IP-anonymization on this website, your IP-address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area. Only in exceptional cases the full IP address will be transferred to a Google server in the USA and shortened there. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other data from Google.

 

During your website visit the following data will be collected:

 

  • the pages you call up, your "click behaviour“
  • Achievement of "website goals" (conversions, e.g. newsletter registrations, downloads, purchases)
  • Your user behavior (for example clicks, dwell time, bounce rates)
  • Your approximate location (region)
  • Your IP address (in abbreviated form)
  • technical information about your browser and the end devices you use (e.g. language settings, screen resolution)
  • Your internet provider
  • the referrer URL (via which website/advertising medium you came to this website)

 

Purposes of processing

On behalf of the operator of this website, Google will use this information to evaluate your (pseudonymous [NOT USER ID]) use of the website and to compile reports on website activity. The reports provided by Google Analytics serve to analyse the performance of our website [OPTIONAL] and the success of our marketing campaigns.

 

Recipient

The data recipient is

 

    Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

 

as data processor. For this purpose we have concluded a contract with Google. Google LLC, headquartered in California, USA, and, if applicable, US authorities can access the data stored at Google.

 

Transfer to third countries

A transfer of data to the USA cannot be excluded.

 

Duration of storage

The data sent by us and linked to cookies is automatically deleted after 14 months. Data is automatically deleted once a month as soon as the storage period is reached.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by

a. not giving your consent to the setting of the cookie or

b. downloading and installing the browser add-on to disable Google Analytics HERE.

 

By setting your browser software accordingsly you can also prevent the storage of cookies. If your browser is set to refuse all cookies, the functionality of this and other websites may be limited.

 

Legal basis and right of withdrawal

Your consent ist he legal basis for this data processing, Art.6 para.1 S.1 lit.a DSGVO. You can revoke your consent at any time with effect for the future by changing your selection in the cookie settings [HERE LINK TO CONSENT TOOL SETTINGS].

 

For more information about Google Analytics terms of use and Google's privacy policy, please visit www.google.com/analytics/terms/de.html and https://policies.google.com/?hl=de.

 

5.1.2. Bing Ads Conversion Tracking

This website uses Bing Ads Conversion Tracking, a search engine service from Microsoft.

 

Purpose of processing

In order to draw attention to our services, we place Bing Ads. These ads are displayed in the Bing, Yahoo! and MSN search engines after searches in the Yahoo! bing network. This also gives us the opportunity to combine our ads with specific search terms and thus we are present on all major search engines.

Bing Ads also uses cookies to analyze user behavior. By clicking on an ad or visiting our website, Bing Ads places a cookie on the user's computer. This information is used to be able to target the visitor in a later search request.

For more information, please visit Microsoft's Privacy Policy and the Privacy and Security Policy.

In addition, we use Bing Ads Conversion Tracking to display interest-based advertising for Bing Ads. This requires also an analysis of user behavior. Bing only provides us with the information that a user has clicked on an ad and that the user has been redirected to our websites. We use the information obtained in this way only for statistical evaluation for ad optimization. We are not able to identify the visitor through the collected data. The statistics provided to us by Bing include the total number of users who clicked on one of our ads. In addition, we also receive information about whether these visitors have been redirected to a page of our website that has been tagged with a conversion tag. These statistics enable us to track which search terms have led to a particularly high number of clicks on our ads and which ads lead to users contacting us via the contact form. The purpose of the Bing Ads Conversion Tracking is to display interest-related advertisements, to make our website more interesting for you and to achieve a more economic assessment of our advertising costs.

Recipient

The data recipient is Microsoft Corporation, One Microsoft Way, Redmont, WA 98052-6399, USA.

Transfer to third countries

Data that have reached their retention period are automatically deleted once a month.

A transfer of data to the USA cannot be excluded.

Storage period

You can find further information about the storage period at privacy.microsoft.com/de-de/privacystatement.

Legal basis and right of withdrawal

The legal basis for this data processing is your consent, Art.6 para.1 S.1 lit.a DSGVO. You can withdraw your consent at any time with effect for the future by accessing the cookie settings [LINK] and changing your selection.

 

 

5.1.3. Google Maps Plug-In

On our website we use the map service Google Maps.

 

Purpose of processing

The purpose of processing the collected data is to display the location of the website operator.

 

Scope of processing

When you use the functions of Google Maps, information, including the IP address and the address entered as part of the route function, may be transmitted to the provider's servers. This information is usually transferred to a Google server in the USA and stored there. When you visit a website that contains Google Maps, your browser establishes a direct connection with the Google servers, whereby the map content is sent to your browser and incorporated by it. The provider of this site has no influence on this data transfer. According to current knowledge, this includes the following data:

- Date and time of your visit to the website in question,

- Internet address or URL of the web page called up,

- IP address, (start) address entered during route planning

 

Recipient

The data recipient is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

 

Transfer to third countries

A transfer of data to the USA cannot be excluded.

 

Legal basis and right of withdrawal

The legal basis for this data processing is your consent, Art.6 I sentence 1 lit.a DSGVO. You can withdraw your consent at any time with effect for the future by changing the cookie settings (here link to the setting options of the content tool). The data will not be collected without your consent.

You can find more information in Google's privacy policy: www.google.de/intl/de/policies/privacy/.

Option to object (Opt Out): Opt-Out-Plugin: tools.google.com/dlpage/gaoptout

Settings for the display of advertisements: adssettings.google.com/authenticated

 

5.1.4. Google Ads remarketing and conversion tracking

We use Google Ads. Google Ads is an online advertising program of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").

 

Scope of processing

We place ads of Google Ads and use Google Remarketing and conversion tracking. The ads are displayed after search requests on websites of the Google advertising network. We also use ad remarketing lists these requests. This enables us to adapt search ad campaigns for users who have visited our website before.

If you reached our website via a Google ad, a cookie is set on your PC by Google Ads. However, the cookies are not intended to identify you personally.

We use the function 'anonymizeIP' (so-called IP-Masking): Due to the activation of IP-anonymization on this website, your IP-address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area. Only in exceptional cases the full IP address will be transferred to a Google server in the USA and shortened there. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other data from Google.

Purposes of processing

Due to the Google Ads services as well as remarketing and conversion tracking, we have the ability to combine our ads with specific keywords or to set ads for previous visitors, e.g. advertising services that visitors have viewed on our site. This allows us to show users of our site interest-based advertising on other websites within the Google advertising network (as "Google ads" within Google Search or on other sites). Using this technology, Google and we as a customer receive information about when a user has clicked on an ad and has been directed to our website.

The information collected by the particular cookie is used in order to be able to address the visitor pointedly in a subsequent search request.

The information obtained in this way is used exclusively for statistical evaluation for ad optimization. We do not receive any information with which visitors can be personally identified. Your IP address is transmitted to Google. However, since we use Google's IP masking on this website, your IP address is anonymized. The statistics provided to us by Google include the total number of users who clicked on one of our ads and, if applicable, whether they were redirected to a page of our website marked with a conversion tag. These statistics enable us to determine which search terms lead to the most frequent clicks on our ads and which ads lead to the user contacting us via the contact form.

Further information on data protection in the context of Google Ads can be found at: policies.google.com/technologies/ads

 

Recipient

The data recipient is

Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland

as data processor. For this purpose we have concluded a contract with Google. Google LLC, headquartered in California, USA, and, if applicable, US authorities can access the data stored at Google.

 

Transfer to third countries

A transfer of data to the USA cannot be excluded.

 

Duration of storage

The cookies usually lose their validity after 30 days.

If you do not want your data to be processed, you can prevent the cookies required for these technologies from being saved, for example, by changing the settings of your browser. In this case your visit will not be included in the user statistics.

 

You can also select the types of Google ads or deactivate interest-based ads on Google via the ad settings (https://adssettings.google.com/authenticated?hl=de). Alternatively, you can disable the use of cookies by third parties by visiting the Network Advertising Initiative's opt-out help page.

However, we and Google will continue to receive statistical information about how many users have visited this site and when. If you do not wish to be included in these statistics either, you can prevent this by using additional programs for your browser (e.g. the Privacy Badger add-on).

 

Legal basis and right of withdrawal

Your consent represents the legal basis for this data processing, Art.6 para.1 p.1 lit.a DSGVO. You can withdraw your consent at any time with effect for the future by changing the cookie settings [HERE LINK TO SETTINGS

 

For more information on Google Ads terms of use, opt-out and opt-in options, and privacy, please visit

policies.google.com/privacy or

services.google.com/sitestats/de.html.

 

5.1.5. LinkedIn Insights Tag and Conversion Tracking

Data collected:

We use LinkedIn’s Insight Tag on this website. The LinkedIn Insight Tag generates a LinkedIn “browser cookie” that collects the following data:

  • IP address,
  • Timestamp,
  • Page activities,
  • demographic data from LinkedIn if the user is an active LinkedIn member.

This technology enables us to monitor the performance of our ads and read information regarding user interaction on our website. The LinkedIn Insight Tag is embedded on our website in order to connect to the LinkedIn Server if and when you visit our site and are logged into your LinkedIn Account while doing so.

Purposes for which the data is processed:

We process your data in order to evaluate campaigns and collect information about users who might have reached our website via our LinkedIn campaigns.

Legal basis:

We process your data because you have given your consent and we have a legitimate interest in processing your data, Art. 6 (1)(a) and (f) EU GDPR.

Storage period and control options:

We store your data for as long as we need it for the respective purpose (evaluation of campaigns) and/or as long as you haven’t objected to the storage of your data or revoked your consent.

The collected data is encrypted. Find more information here. Have a look at LinkedIn’s privacy policy and the LinkedIn Opt-Out.

 

5.2 TO PERFORM A CONTRACT (ART. 6 PARA. 1 B GDPR)

We use your personal data to process customer and supplier orders. Within the contractual relationship, we particularly process your data to perform the following activities:

  • Contract related contact
  • Order management
  • Purchasing
  • Delivery and billing
  • Ongoing customer service and supplier relations
  • Fulfillment of warranty claims 
  • Claims management

You can find more detailed information about the purposes for data processing in the respective contractual documents and General Terms and Conditions.

5.3 TO COMPLY WITH LEGAL OBLIGATIONS (ART. 6 PARA. 1 C GDPR) OR IN THE PUBLIC INTEREST (ART. 6 PARA. 1 E GDPR)

As a company, we are subject to various legal obligations. To fulfill these obligations, it may be necessary to process personal data:

  • Monitoring and reporting obligations
  • Creditworthiness, age, and identity checks
  • Prevention of/defense against criminal actions

5.4 ON THE BASIS OF A LEGITIMATE INTEREST (ART. 6 PARA 1 F GDPR)

In certain cases, we process your data to protect a legitimate interest of ourselves or of a third party.

  • Central customer data administration within the Group of companies
  • Measures for building and facility security
  • Video monitoring to protect the right to grant or deny building access
  • Consultation of and data exchange with credit agencies
  • To determine creditworthiness or default risks
  • To ensure IT security and IT operations
  • Sending an email newsletter to existing customers
  • The use of cookies that are necessary to provide our services on our homepage.

5.5 TO DECIDE WHETHER TO ESTABLISH AN EMPLOYMENT RELATIONSHIP (SEC. 26 PARA. 1 P. 1 GERMAN FEDERAL DATA PROTECTION ACT)

  • The legal basis for processing your application data is Sec. 26 para. 1 clause 1 German Federal Data Protection Act (BDSG). Accordingly, personal data may be processed for purposes of the employment relationship, if this is necessary for the decision about whether to establish an employment relationship.

6 TO WHOM WILL WE DISCLOSE YOUR DATA?

If necessary to fulfill our contractual and legal obligations, your personal data will be disclosed to the following public or internal bodies or external service providers.

Companies within the Group of companies:

TER HELL & Co. GmbH contains a central customer/supplier data administration that employees of the major Group companies may access. The companies of the TER Group can access it at our website, www.tergroup.com.

External service providers:

  • IT service providers (e.g. maintenance providers, hosting providers)
  • Service providers for file and data destruction
  • Printing service providers
  • Telecommunication
  • Payment service providers
  • Consulting
  • Service providers for marketing or sales
  • Credit agencies
  • Distributors
  • Web hosting service providers
  • Certified accountants

Public bodies:

We may also be obligated to disclose your personal data to other recipients, such as to the authorities, to fulfill statutory reporting obligations.

  • Fiscal authorities
  • Customs authorities
  • Social insurance agencies

7 WILL YOUR DATA BE TRANSMITTED TO COMPANIES OUTSIDE OF THE EUROPEAN UNION (THIRD PARTY COUNTRIES)?

Countries outside of the European Union (and the European Economic Area "EEA") handle the protection of personal data differently than countries in the European Union. To process your data, we also use service providers that are located in third party countries outside of the European Union. At the present time, the EU Commission has not issued a resolution that these third party countries generally offer an appropriate level of protection.

For this reason, we have taken special measures to ensure that your data is processed exactly as securely in these third party countries as it is within the European Union. With service providers in third party countries, we conclude the standard data protection clauses provided by the Commission of the European Union. These clauses stipulate appropriate guarantees for the protection of your data with service providers in third party countries.

Our service providers in the USA are also certified in accordance with the EU-US Privacy Shield agreement.       

If you would like to view the present guarantees, please contact us at Data.Protection@tergroup.com.

8 HOW LONG WILL YOUR DATA BE STORED?

We store your data for as long as is necessary for the fulfillment of our statutory and contractual obligations.

If it is no longer necessary to store the data for the fulfillment of contractual or legal obligations, your data will be deleted unless its continued processing is necessary for the following purposes:

  • Fulfillment of corporate and tax law retention obligations. This includes retention periods pursuant to the German Commercial Code (HGB) or the German Tax Code (AO). The retention periods extend for up to 10 years.
  • Retention of evidence in the context of legal statutes of limitations. According to the statutes of limitations of the German Civil Code (BGB), these periods of limitation may be up to 30 years in some cases, while the standard period of limitation is three years.
  • Your application data will be deleted 6 months after the application procedure is concluded. If it is necessary to store it for a longer period, we will ask you for written consent.
  • Anonymized user data that is collected by Google Analytics is deleted after 14 months.

9 WHAT RIGHTS DO YOU HAVE IN CONNECTION WITH THE PROCESSING OF YOUR DATA?

Every affected person has the right of access pursuant to Art. 15 GDPR, the right to rectification pursuant to Art. 16 GDPR, the right to erasure pursuant to Art. 17 GDPR, the right to restriction of processing pursuant to Art. 18 GDPR, the right to object pursuant to Art. 21 GDPR, and the right to data portability pursuant to Art. 20 GDPR.

9.1 RIGHT TO OBJECT

You can object to the use of your data for advertising purposes at any time, and no costs may arise beyond the communication costs according to base rates. In particular, you can unsubscribe from the email newsletter by clicking the provided link at the end of the newsletter.

What rights do you have in cases when data is processed on the basis of a legitimate or public interest?

Pursuant to Art. 21 para. 1 GDPR, you have the right, for reasons resulting from your specific situation, to make an objection to the processing of your personal data that occurs on the basis of Art. 6 para. 1 e GDPR (Data processing in the public interest) or on the basis of Art. 6 para. 1 f GDPR (Data processing to protect a legitimate interest), which also applies to profiling based on one of these regulations.

In the event that you object, we will no longer process your personal data unless we can prove necessary legitimate reasons for processing that outweigh your interests, rights, and freedoms, or if processing serves the assertion, exercise, or defense of legal claims.

What rights do you have in cases of data processing to operate direct marketing?

Inasmuch as we process your personal data to operate direct marketing, you have the right pursuant to Art. 21 para. 2 GDPR to make an objection to the processing of your personal data for purposes of direct mail advertising at any time; this also applies to profiling in connection with such direct marketing.

In the event that you object to processing for purposes of direct marketing, we will no longer process your data for these purposes.

9.2 WITHDRAWING CONSENT

You may withdraw your consent to the processing of your personal data at any time. Please note that this withdrawal only affects the future. In particular, you can unsubscribe from the email newsletter by clicking the provided link at the end of the newsletter.

You can prevent the collection of data that relates to the use of the website (incl. your IP address) by Google Analytics and the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout

9.3 RIGHT TO ACCESS

You can request confirmation as to whether we have stored personal data about you. If you request it, we will tell you for what data this is the case, for what purposes the data was processed, to whom the data was disclosed, for how long the data will be saved, and what rights you have in connection with this data.

9.4 OTHER RIGHTS

You also have the right to rectification of incorrect data or deletion of your data if one of the prerequisites pursuant to Art. 17 para. 1 GDPR is present. If there is no reason for data to continue to be stored, we will delete your data; otherwise, we will restrict processing. You can also request that we provide all personal data that you have provided to us to yourself or to a person or company of your choice in a structured, comman, and machine readable format.

You also have a right to complain to the responsible data protection authorities (Art. 77 GDPR).

9.5 ASSERTING YOUR RIGHTS

To assert your rights, you can contact the controller or the Data Protection Officer under the indicated contact information, particularly at: Data.Protection[at]tergroup.com. We will process your inquiries immediately and in accordance with the statutory provisions and will tell you what measures we have taken.

10 IS THERE AN OBLIGATION TO PROVIDE YOUR PERSONAL DATA?

To enter into a business relationship, you must give us some of your personal data that is necessary for the performance of the contractual relationship or that we must collect due to legal regulations. If you do not provide this data to us, it is not possible for us to perform and process the contractual relationship.

11 DATA COLLECTION AND PROCESSING ON OUR WEBSITES

When you visit our websites, we temporarily store some general technical information, such as the software and hardware you use, the IP address of the requesting computer, the Internet site from which you are visiting us, the pages you visit, and the date, time and duration of your visit. We collect this data exclusively to ensure the functionality of our websites.

On our websites, we use cookies to facilitate the use of certain functions. Cookies are files that are stored on the hard drive of your computer and make navigation easier. They prevent all necessary data from having to be entered again for each new use. Cookies help us to adapt our websites to your needs, such as to your national language.

Inasmuch as the use of cookies is necessary to provide our services, this use is based on a legitimate interest pursuant to Art. 6 para. 1 clause f) GDPR.

If you have given your consent, Google Analytics, a web analysis service provided by Google Inc. ("Google") will be used on these websites. Google Analytics uses "cookies," which are text files that are saved on your computer and facilitate analysis of your use of the website. The information about your use of the website that is recorded by the cookie will generally be transferred to a Google server in the USA and stored there. In the event that IP anonymization is activated on this website, your IP address will first be shortened by Google within member states of the European Union or other contracting states of the treaty concerning the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to create reports about website activities, and to perform other services connected with website usage and internal usage for the website operator. The IP address transmitted from your browser in the context of Google Analytics will not be collated with other data from Google. You can prevent cookies from being stored by using the setting in your browser software; however, we must inform you that it may not be possible to fully use all functions of this website in this case. You can also prevent data that is created by cookies and relates to your usage of the website (incl. your IP address) from being sent to Google and this data from being processed by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout

You can find more detailed information about usage conditions and data protection under Google Analytics Conditions and under the Google Analytics Overview. We would like to inform you that on this website, Google Analytics has been expanded using the code "ga('set', 'anonymizeIp', true)" to ensure that IP addresses are recorded in an anonymized form (IP masking).

12 CHANGES TO THIS INFORMATION

If the purpose or type and manner of processing your personal data changes significantly, we will update this information promptly and promptly inform you of the changes.

 

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