Privacy Policy

0. Overview

The Brocco.ly Klinger, Breidert and Schasse de Araujo GbR (“Broccoly", Brocco.ly”, "us", "we", or "our") operates the brocco.ly and www.brocco.ly websites (the "Service").

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.

We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

Our privacy policy is based on the terms used by the European legislator under the General Data Protection Regulation (GDPR).



1. Name of the person responsible

The person responsible within the meaning of the GDPR and other national data protection laws of the member states as well as other data protection regulations is the

 

Brocco.ly Klinger, Breidert und Schasse de Araujo GbR 

℅ Friedrich Klinger

Schönholzer Str. 6

10115 Berlin

 

Phone: +49 1786114830

E-mail: [email protected]

Web: brocco.ly



3. Data protection officer

 

Our data protection officer can be contacted as follows:

 

Brocco.ly Klinger, Breidert und Schasse de Araujo GbR

Datenschutzbeauftragter

℅ Friedrich Klinger

Schönholzer Str. 6

10115 Berlin

 

3. General information about the collection and processing of your data

i) Scope of processing

In principle, we process personal data of our website visitors and users only to the extent necessary for the provision of a functioning website and our content and services. The processing of the personal data of our users is carried out regularly only with the consent of the user. Exceptions are cases in which prior consent cannot be obtained for factual reasons and the processing of the data is legally permissible.

 

ii) Legal basis

Insofar as we obtain the consent of the person concerned for the processing of personal data, Art. 6 §1 GDPR shall apply as the legal basis.

 

When processing personal data, which are necessary for the fulfilment of a contract, in which the person concerned is involved, Art. 6 § 1 lit. b GDPR applies as a legal basis. This also applies to processing, which is necessary for the execution of pre-contractual measures.

 

As far as the processing of personal data is necessary for the fulfilment of a legal obligation which is subject to our company, Art. 6 § 1 lit. b GDPR is applicable. c GDPR as legal basis.

 

In the case that vital interests of the person concerned or another natural person require the processing of personal data, Art. 6 § 1 lit. d GDPR is the legal basis.

 

If the processing is necessary in order to protect the legitimate interests of our company or a third party, and if the interests, fundamental rights and freedoms of the person concerned do not have priority over the first interest, Art. 6 § 1 lit. f GDPR shall apply as the legal basis for the processing.

 

iii) Storage and deletion of your data

We delete or block the personal data of the person concerned as soon as the purpose of storage has been removed. They may also be stored if the European or national legislator provides for this in EU regulations, laws or regulations to which our company is subject. The data will be blocked or deleted even after the expiry of a retention period prescribed by the aforementioned standards, unless there is a need for further storage of the data for the conclusion of a contract or the fulfilment of the contract.






4. Provision of the website and creation of log files

i) Scope of processing

Each time you access our website, our system automatically collects data and information from the calling computer's computer system. This includes, for example, information such as

 

- Information about the type and version of your Internet browser,

- The operating system of your computer or smartphone,

- Your Internet service provider,

- Your IP address,

- Date and time of your access,

- Websites from which you have come to us,

- Websites that you visit from our website.

- The legal basis for interim storage is Art. 6 § 1 lit. f GDPR.

 

We collect this technical information in so-called "log files" so that you can display our website correctly and we can identify the causes of technical problems, for the technical optimisation of our websites and for the purpose of the security of our computer systems and networks. For these purposes, our legitimate interest in the processing of data pursuant to Art. 6 § 1 lit. f GDPR.

 

The data will be deleted as soon as they are no longer required for the purposes of collection. As a rule, this technical information is deleted or made unrecognisable at the latest after seven days.

 

The collection of data for the provision of the website and the storage of data in log files is essential for the operation of the website. There is therefore no objection on the part of the user.



5.Contact request for waiting list, feedback, or other concerns

i) Scope and Description of data processing

On our website you can contact us via different ways: e.g. contact form. If you make this possible, the data entered in the input mask will be transmitted to us and stored. In addition to the specific input macro data, the IP address and the date and time of the request are recorded and stored. You give your consent to the processing of the data during the transmission process.

 

Alternatively, it is also possible to contact us by e-mail. In this case, the personal data of the user transmitted by e-mail will be stored.

 

The data will not be passed on to third parties in this context, unless this is necessary for processing the request (e.g. sign up for waiting list).

 

ii) Legal basis for processing

Legal basis for the processing of the data is in the presence of the consent of the user art. 6 § 1 lit. a GDPR.

 

The legal basis for the processing of the data transmitted in the course of sending an e-mail is article 6 (1) lit. f GDPR. If the e-mail contact aims to conclude a contract, then additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.

 

iii) Purpose of the data processing

The processing of personal data from the input mask is solely for the processing of your request. In the case of contact via e-mail, this also includes the required legitimate interest in the processing of the data.

 

The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

 

iv) Duration of storage

If you have signed up for the waiting list or sent us feedback on a service, we reserve the right to store the data for ten years to measure conversions and improve our service. Otherwise, we will delete the data as soon as it is no longer necessary to achieve the purpose of its collection. For the personal data from the input form of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the relevant facts have been finally clarified.

 

The additional personal data collected during the sending process will be deleted at the latest after a period of seven days.

 

v) Opposition and removal possibility

The user has the possibility at any time to revoke his consent to the processing of the personal data. If the user contacts us by e-mail, he may object to the storage of his personal data at any time. In such a case, the conversation can not continue.

 

All personal data stored in the course of contacting will be deleted in this case.




You become a customer, partner, or user of Brocco.ly

i) Description and scope of data processing

We offer the possibility of becoming a customer, partner, or user by providing personal data. The data is collected and stored in the sign up process and during the time you use the product or send us your data. A transfer of data to third parties does not take place. The following data is collected during the process:

 

- Your email address,

- First name and last name,

- Payment information,

- Biometrics like your weight and height,

- Your answers to our questionnaires,

- Your lab results (especially but not only blood biomarkers),

- other data that we request from you, and

- possibly data that we receive in the course of the business-customer relationship.

 

ii) Legal basis for processing

Legal basis for the processing of the data is in the presence of the consent of the user art. 6 § 1 lit. a GDPR and art. 6 §1 lit. b GDPR, since the registration of the fulfillment of a contract or the implementation of pre-contractual measures.

 

iii) Purpose of the data processing

The data is required to fulfill the customer, user, or partner contract. It is used to make an analysis for informational purpose. Also, it is used to create new insights and correlations to improve our service.

 

iv) Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. This is the case if it is no longer needed for the purpose of the contract and for the purpose of analysis to improve our service. Even after the conclusion of the contract, there may be a need to store personal data of the contracting party in order to comply with contractual or legal obligations. In particular, our company has to observe the storage obligations of § 257 Commercial Code in this connection.

 

v) Opposition and removal possibility

As a user you always have the option to cancel your account. You can change the data stored about you at any time. If the data is required to fulfill a contract or to carry out pre-contractual measures, premature deletion of the data is only possible, unless contractual or legal obligations preclude deletion.



7. Cookies and tracking technologies

i) What are Cookies?

Web-Browser-Cookies

A web browser cookie is a small text file sent from a website to your computer or mobile device where it is stored by your web browser. Web browser cookies may store information such as your IP address or other identifier, your browser type, and information about the content you display and interact with on the digital services. By storing such information, web browser cookies can store your preferences and settings for online services and analyze how you use online services.

 

Tracking Technologies: Web Beacons / Gifs, Pixels, Page Tags, Script

Emails and mobile applications can contain small, transparent image files or lines of code to record how you interact with them. This information is used to help website and app publishers better analyze and improve their services.

 

ii) Use, legal basis and purpose

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser be identified even after a page break.

In addition, we use cookies on our website that allow an analysis of users' browsing behavior.

 

When accessing our website, the user is informed about the use of cookies for analysis purposes and his consent to the processing of the personal data used in this context is obtained. In this context, there is also a reference to this privacy policy.

 

The legal basis for the processing of personal data using technically necessary cookies is Article 6 (1) lit. f GDPR.

 

The legal basis for the processing of personal data using cookies for analysis purposes is the consent of the user Art. 6 para. 1 lit. a GDPR.

 

The purpose of using technically necessary cookies is to facilitate the use of websites for users. Some features of our website can not be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page break. We require cookies for the following applications: Acceptance of language settings. The user data collected through technically necessary cookies will not be used to create user profiles.

 

The use of the analysis cookies is for the purpose of improving the quality of our website and its contents. Through the analysis cookies, we learn how the website is used and so we can constantly optimize our offer.

 

iii) Duration of storage, objection and disposal options

Cookies are stored on the computer of the user and transmitted by this on our side. Therefore, as a user, you have full control over the use of cookies. By changing the settings in your internet browser, you can disable or restrict the transmission of cookies. Already saved cookies can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, it may not be possible to use all the functions of the website to the full.

 

8. Implemented technologies

 

Google Tag Manager

Follow this link to read the privacy statement of the data processor. Google Tag Manager @ https://policies.google.com/privacy

We use the Google Tag Manager. The operating company of the Google Tag Manager component is Alphabet Inc. This service enables the management of website tags via an interface. The Google Tag Manager implements tags only. This means that no cookies are used and no personal information is collected. The Google Tag Manager triggers other tags that can collect data. However, the Google Tag Manager does not access this data. If deactivated at the domain or cookie level, it will remain valid for all tracking tags when implemented with the Google Tag Manager.



Google Analytics Statistics

Follow this link to read the privacy statement of the data processor. Google Analytics Statistics @ https://policies.google.com/privacy

 

1. Description

We use Google Analytics to analyse the traffic on our website. Web Analytics is the collection, collection and analysis of data about the behaviour of visitors to websites.

 

2. Operating company

The operating company is Alphabet Inc. Google Analytics is a web analytics service.

 

3. Purpose of data processing

Web analytics are mainly used to optimize a website and to perform a cost-benefit analysis of Internet advertising. The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information, among other things, to evaluate the use of our website and to provide online reports showing the activities on our websites and to provide other services in connection with the use of our website for us.

 

4. Data collected

Among other things, a web analysis service collects data about the website from which a person came (the so-called referrer), which subpages were visited or how often and for how long a subpage was visited.

 

5. Legal basis for processing

The legal basis for the processing of the data is Art. 6 para. 1 1 lit. a GDPR, if the user has given his consent, and additionally Art. 6 para. 1 1 lit. f GDPR.

 

6. Place of data processing

Through Google Analytics, personal data and information - including the IP address (anonymized) and required for the collection and billing of the displayed advertisements - are transmitted to Alphabet Inc. in the United States of America. This personal data is stored and processed in the United States of America.

 

7. Technology

Cookies

 

8. Storage period

The data are deleted as soon as they are no longer needed for our logging.

 

9. Objection and deregistration

You can permanently prevent cookies at any time by making the appropriate settings in your browser. This would also prevent Google Analytics from setting a cookie. In addition, cookies already used by Google Analytics can be deleted at any time via the browser. In addition, you have the opportunity to object to and exclude the collection of data by Google Analytics in connection with the use of this website and the processing of this data by Google. To do this, you must download and install a browser add-on via the link https://tools.google.com/dlpage/gaoptout. . This browser add-on informs Google Analytics via JavaScript that data and information about visits to websites may not be transmitted to Google Analytics. The installation of the browser add-ons is regarded by Google as a contradiction. If you later delete, reset, or reset your preferences, you will need to reinstall the browser add-on to disable Google Analytics.

 

Heroku

Follow this link to read the privacy statement of the data processor. Heroku @ https://www.heroku.com/policy/security and https://www.salesforce.com/company/privacy/

 

1. Description

We use Heroku to host our code and databases.

 

2. Operating company

The operating company is Salesforce.com Inc. Heroku by Salesforce is a backend and cloud service.

 

3. Purpose of data processing

We use heroku to have a secure and fast cloud storage for our databases and to have our web app distributed and hosted.

 

4. Data collected

All the data points mentioned under “6. You become a customer, partner, or user of Brocco.ly”.

 

5. Legal basis for processing

The legal basis for the processing of the data is Art. 6 para. 1 1 lit. a GDPR, if the user has given his consent, and additionally Art. 6 para. 1 1 lit. f GDPR.

 

6. Place of data processing

Our databases at Heroku are hosted in the United States of America.

 

7. Technology

Cloud storage

 

8. Storage period

The data is stored as described under point “6. You become a customer, partner, or user of Brocco.ly”.

 

9. Objection and deregistration

Heroku is required for our service to run. If you want your data deleted from Heroku you have to delete your account at Brocco.ly and sent and e-mail to [email protected] with your concern.

 

SendGrid

Follow this link to read the privacy statement of the data processor. SendGrid @ https://sendgrid.com/policies/privacy/ and https://www.twilio.com/legal/privacy

 

  1. Description

We use SendGrid for managing automated emails.

 

  1. Operating company

The operating company is TWILIO INC. SendGrid by Twilio is a tool for managing email technologies on scale.

 

  1. Purpose of data processing

Enabling us to send emails to our users.

 

  1. Data collected

E-mail-address, E-mails, IP and more.

 

  1. Legal basis for processing

The legal basis for the processing of the data is Art. 6 para. 1 1 lit. a GDPR, if the user has given his consent, and additionally Art. 6 para. 1 1 lit. f GDPR.

 

  1. Place of data processing

Personal information of you processed by Twilio may be transferred to the United States, where their primary processing facilities are located, and possibly to other countries where they or their service providers operate. These transfers will often be made in connection with routing communications in the most efficient way.

 

Twilio employs appropriate safeguards for cross-border transfers of personal data, as required by applicable local law, including Binding Corporate Rules and the EU-U.S. Privacy Shield and Swiss - U.S. Privacy Shield Frameworks.



  1. Technology

E-Mail

 

  1. Storage period

The data is stored as described under point “5. Contact request for waiting list, feedback, or other concerns”.

 

  1. Objection and deregistration

If you want your data deleted, sent an e-mail to [email protected] with your concern.



Google AdWords Conversion

Follow this link to read the privacy statement of the data processor. Google AdWords Conversion @ https://policies.google.com/privacy

 

  1. Description and scope of processing

We use Google AdWords Conversion for conversion tracking. The operating company is Alphabet Inc. Google AdWords collects user agent, usage data, Google Ad Cookie, conversions, possible turnover and points of contact with advertising material via cookies. These cookies enable Google AdWords to anonymously statistically evaluate your use of our website. As soon as you click on one of our Google AdWords, Google saves a so-called conversion cookie on your computer. These conversion cookies do not serve your personal identification. If you visit certain pages of our website and the conversion cookie has not yet expired, we can anonymously identify which keywords you have used in the Google search engine and that you have been clicked on a specific Google AdWord and forwarded to that page. In addition, the conversion cookie allows us to anonymously recognize when you perform certain conversion actions on our website, in particular by sending a contact form. The anonymous information generated by the cookie is generally transmitted to a Google server in the USA, where it is stored and statistically evaluated by Google. However, Google AdWords Conversion Tracking and Analysis does not provide us with any information that personally identifies the user. Because each AdWords customer receives a different conversion cookie, conversion cookies cannot be tracked across the websites of multiple AdWords customers.

Alphabet Inc. may share the collected personal information with third parties through this technical process.

Google AdWords transfers to Alphabet Inc. in the United States of America personal data and information - including the IP address - that is necessary for the collection and billing of the advertising displayed. This personal data is stored and processed in the United States of America.

 

  1. Legal basis of the processing

Legal basis for the processing of the data is Art. 6 Para. 1 lit. a GDPR, if the user has given his consent.

 

  1. Purpose of the processing

We use the information to generate conversion statistics and to monitor and optimize the quality and success of our AdWords campaigns. For example, we can statistically analyze how many users clicked on which Google AdWords when using which keywords, and how many users clicked on a particular AdWord and performed which conversion actions on our sites.

 

  1. Retention period

The data are deleted as soon as they are no longer needed for our logging. The persistence of the conversion cookies is 30 days.

 

  1. Objection and opt-out

You can permanently prevent the setting of cookies at any time by making the appropriate settings in your browser, so that Google AdWords cannot set a cookie either. You can also only prevent Google AdWords Conversion Tracking from saving the conversion cookies by setting your browser to block cookies from the "www.googleadservices.com" domain. In addition, cookies already used by Google AdWords can be deleted at any time via the browser. How to unsubscribe is also explained in this FAQ by Google: https://support.google.com/ads/answer/2662922?hl=en and this video tutorial by third parties: https://www.youtube.com/watch?v=JBOV5C9PLyA.

 

  1. Further information

For more information about Google's privacy practices, please visit: https://policies.google.com/privacy



9. Minors

Our services are not aimed at children under 13 years. We do not knowingly collect information from children under the age of 13. If you have not reached the age limit, do not use the services and do not provide us with your personal information. If you are a parent of a child below the age limit and you learn that your child has provided Lia’s personal information, please contact us at [email protected] and insist on exercising your rights of access, correction, cancellation and / or opposition. If you are resident in California and are under 18 years of age and wish to erase publicly available content, please contact us at [email protected]



10. Your rights

If we process your personal data you have - after successful identification - the following rights towards us:

 

i) Right to information

You may request confirmation from our company as to whether we process personal information pertaining to you.

 

If such processing is available, you can request information about a large number of circumstances in accordance with GDPR, such as

 

(1) the purposes for which your personal information is processed;

 

(2) the categories of personal data being processed;

 

(3) the recipients or categories of recipients to whom your personal information has been disclosed or is still being disclosed;

 

(4) the planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the retention period;

 

(5) the existence of a right to rectification or deletion of your personal data, a right of limitation of our processing or a right to object to such processing;

 

(6) the existence of a right of appeal to a supervisory authority;

 

(7) all available information about the source of your personal data, unless your personal information was collected from yourself;

 

(8) the existence of automated decision-making including profiling under article 22 (1) and (4) GDPR and, at least in these cases, meaningful information about the logic involved, and the scope and intended impact of such processing on the data subject.

 

You have the right to request information about whether your personal information relates to a third country or an international organization. In this connection, you can request the appropriate guarantees in accordance with. Art. 46 GDPR in connection with the transfer.

 

ii) Right to rectification

You have the right to correct and / or complete your personal data if this information is incorrect or incomplete. We will make the correction without delay.

 

iii) Right to restriction of processing

Under certain circumstances, you may request the restriction of the processing of your personal data.

 

(1) if you contest the accuracy of your personal information for a period of time that enables us to verify the accuracy of your personal information;

 

(2) if the processing is unlawful and you refuse the deletion of your personal data and instead request the restriction of the use of your personal data;

 

(3) If we no longer need your personal information for the purposes of processing, but you need it to assert, exercise or defend your rights, or

 

(4) if you object to the processing and it is not yet certain that the legitimate reasons of our group of companies and affiliates exceed your reasons.

 

If the processing of your personal data has been restricted, we may only process this data - with the exception of its storage - with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

 

If the limitation of the processing after the o.g. If conditions are restricted, you will be informed by us before the restriction is lifted.

 

iv) Right to cancellation

You may require us to have your personal information deleted immediately and we shall be obliged to erase that information immediately if one of the following is true:

 

(1) your personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

 

(2) You revoke your consent, to which the processing acc. art. 6 § 1 lit. a or art. 9 § 2 lit. GDPR and there is no other legal basis for processing.

 

(3) According to art. 21 §1 GDPR objection to the processing and there are no prior justifiable reasons for the processing, or art. 21 § 2 GDPR.

 

(4) Your personal data have been processed unlawfully.

 

(5) The deletion of personal data concerning you shall be required to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.

 

Have we made your personal data public and we are gem. Article 17 (1) of the GDPR requires that we take appropriate measures to inform other companies processing your personal data that you have deleted all links to yours, taking into account available technology and implementation costs personal data (and all copies thereof) ("right to be forgotten"). The right to erasure does not exist if the processing is necessary.

 

(1) to exercise the right to freedom of expression and information;

 

(2) to fulfill a legal obligation required by the law of the Union or of the Member States to which the controller is subject, or to carry out a task which is in the public interest or in the exercise of official authority conferring on the controller has been;

 

(3) for reasons of public interest in the field of public health pursuant to art. 9 (2) lit. h and i as well as art. 9 (3) GDPR, or

 

(4) to assert, exercise or defend legal claims.

 

v) Right to information of third parties by our company

If you have the right to rectify, delete or restrict the processing to our company, we are obliged to notify all recipients to whom we have disclosed your personal data this rectification or deletion of the data or restriction of processing, unless this proves to be impossible or involves a disproportionate effort. You also have the right to be informed by us about these recipients.

 

vi) Right to Data Portability

You have the right to receive personally identifiable information you provide us in a structured, common and machine-readable format. You also have the right to transfer this information to another person without hindrance by the controller to whom the personal data has been provided, provided that

 

(1) the processing on a consent acc. art. 6 §1 lit. a GDPR or art. 9 § 2 lit. a GDPR or on a contract acc. art. 6 § 1 lit. b GDPR is based and

 

(2) the processing is done by automated means.

 

In exercising this right, you also have the right to obtain that your personal data relating to you are transmitted directly from one person to another, insofar as this is technically feasible. Freedoms and rights of other persons may not be affected.

 

The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the controller.

 

vii) Right to object

You have the right at any time, for reasons that arise from your particular situation, against the processing of your personal data, which pursuant to art. 6 § 1 lit. e or f GDPR takes an objection; this also applies to profiling based on these provisions.

 

We will no longer process your personal information in this case unless there are compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purpose of enforcing, pursuing or defending legal claims.

 

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct mail.

 

If you object to processing for direct marketing purposes, we will no longer process your personal data for these purposes.

 

viii) Right to revoke the data protection consent declaration

You have the right to revoke your data protection declaration at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.

 

ix) Automated decision on a case-by-case basis, including profiling

You have the right not to be subjected to a decision based solely on automated processing - including profiling - that will have legal effect or similarly affect you in a similar manner.

 

This does not apply if the decision

 

(1) is required for the conclusion or performance of a contract between you and us,

 

(2) is permitted by Union or Member State legislation to which the controller is subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and legitimate interests, or

 

(3) with your express consent.

 

With respect to the cases referred to in (1) and (3), the person responsible shall take reasonable steps to uphold the rights and freedoms and your legitimate interests, including at least the right to intervene in the intervention of a person of our company in order to express his or her own position and to challenge it heard of the decision.

 

x) Right to complain to the supervisory authority

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of its residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against GDPR. Names and contact information of the competent supervisory authorities in the European Union can be found at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm

 

The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Article 78 of the GDPR.



Security and integrity of the data

Protecting the information you give us or that we receive about you is our priority. We take appropriate security measures to protect your information from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. Brocco.ly has taken measures to ensure the ongoing confidentiality, integrity, availability and resiliency of systems and services that process personal information, and will restore the availability and access to information in the event of a physical or technical incident in a timely manner.



Updates

We reserve the right to update this privacy policy from time to time. In the event that we make material changes that restrict Brocco.ly’s rights or obligations under this Privacy Policy, we will publish a clear notice in this section of this Privacy Policy that informs users when they are updated.