Privacy Policy
INTELLIGENTSIA COFFEE, INC. PRIVACY POLICY
Effective Date: March 7, 2024
Intelligentsia understands that you care about privacy, so we are committed to helping you understand your privacy rights and how we use information about our site visitors. This Privacy Policy describes the types of information we collect, how we may use that information, to whom and under what circumstances we may disclose it, and how we protect it. We also tell you how to update your information or contact us with questions about our privacy practices. This Privacy Policy applies only to information we collect on this website (www.intelligentsia.com), including the chat feature on this website, our mobile sites and mobile applications, and our social media accounts (collectively, the “Sites”), and any other personal information obtained when you call, email, visit our stores, or otherwise communicate or interact with Intelligentsia. BY ACCESSING THE SITES ON ANY COMPUTER, MOBILE PHONE, TABLET, OR OTHER DEVICE (COLLECTIVELY, “DEVICE”), MAKING A PURCHASE FROM INTELLIGENTSIA, OR OTHERWISE INTERACTING WITH INTELLIGENTSIA, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY. If you do not agree to the policy, please do not use the Sites.
WE SUGGEST YOU REVIEW THIS PRIVACY POLICY PERIODICALLY, AS IT MAY BE UPDATED FROM TIME TO TIME. WE WILL POST A CURRENT VERSION ON THE SITES.
INFORMATION WE COLLECT AND HOW WE USE AND SHARE IT
For the 12-month period prior to the date of this Privacy Policy, we explain here what categories of personal information we have collected, where we got it from, and with whom we have shared it:
|
Category of Personal Information Collected |
Source of information |
Purpose for Collection |
Categories of recipients |
|
CONTACT INFORMATION: such as your name, billing address, shipping address, email address, telephone numbers, or other contact information |
From you; the decision to provide this information is typically optional, however, if you choose not to provide the requested information, you may not be able to use some or all of the features of our Sites |
To communicate with you, for product fulfillment and shipping, to send you catalogs, information, newsletters, promotional materials and other offerings from Intelligentsia or on behalf of our partners and Affiliates, to offer a sweepstakes, contest or other promotion, Intelligentsia card reloads, when you contact us, when you request customer service or support, to complete your registration on our Sites, to administer your account(s) with us, and to provide you with offers that may be of interest to you |
Our affiliates and subsidiaries, including Peet’s Coffee, Inc., Mighty Leaf Tea, and Stumptown Coffee Corp. (collectively, “Affiliates”); our trusted service providers |
|
PURCHASE AND ORDER INFORMATION: contact information, together with purchase details online and in store through e-receipts, delivery details, payment details, Intelligentsia card information, any communications we have received about your order or purchase |
From you |
To validate, confirm, verify, deliver, install, and track your order, including to arrange for shipping, handle returns and refunds, maintain a record of the purchases you make, to service products you purchased from us, to gather feedback on our stores, products and the Sites, and to provide you offers that may be of interest to you |
Our Affiliates; service providers who process, fulfill and ship orders |
|
OTHER DELIVERY INFORMATION: name and address of recipient for delivery, if different from customer’s |
From you |
To deliver to the person at the address which you have requested |
Our Affiliates; service providers who process, fulfill and ship orders |
|
PAYMENT INFORMATION: name, card issuer and card type, credit or debit card number, expiration date, CVV code and billing address |
From you and your payment card issuer |
To check that the right person is using the right card or account, meet the requirements of the card brands or account issuers, and to make sure we are paid for what you buy |
Our Affiliates; service providers who process payments for us; these third-party service providers are prohibited from using personal information for any other purpose and are contractually required to comply with all applicable laws and requirements, which may include Payment Card Industry Data Security Standards if they are processing payments for Intelligentsia |
|
REWARDS INFORMATION: your rewards account number, birthday, gender, age, purchase history and information on rewards or other benefits |
From you when you sign up for our rewards program and from our rewards service provider |
To administer your rewards account and provide you with offers that may be of interest to you |
Our Affiliates; service providers who administer our rewards program and our co-marketing partners |
|
INFORMATION YOU PROVIDE ABOUT A THIRD PARTY: if you send someone else a communication from the Sites (such as sending a gift or virtual gift card), we may collect information such as that person's name, telephone number, email, and/or shipping address. |
From you |
To deliver to or communicate with the person at the address which you have requested |
Our Affiliates; service providers and our co-marketing partners |
|
SOCIAL MEDIA: information about you, including Usage Data and personal information such as lists of your friends, "likes", comments you have shared, groups and location |
From third parties, particularly social media platforms |
To enhance your online shopping experience, including as a way to recognize you and welcome you to the Sites, to provide you with customized Sites content, targeted offers, promotions and advertising on the Sites, through other third party sites or apps, via email, text messages, or app push notifications that are offered by Intelligentsia or other marketing partners that might be of interest to you. |
Our Affiliates; service providers and our co-marketing partners |
|
LEGAL INFORMATION: fraud checks or flags raised about your transactions, the payment card you want to use, payment card refusals, suspected crimes, complaints, claims and accidents |
From you, the police, crime and fraud prevention agencies, payment card providers, the public, regulators, your and our professional advisors and representatives |
To protect you, other customers and our business against criminal activities and risks, unauthorized use, and make sure we understand and can meet our legal obligations to you and others and can defend ourselves |
Our Affiliates; service providers who help us with fraud protection and credit risk reduction, law enforcement and other governmental authorities in accordance with applicable law. |
|
PREFERENCE INFORMATION: your marketing preferences, your account settings including any default preferences, any preferences you have indicated, the types of services/offers that interest you, or the areas of our Sites that you visit |
From you, from our Sites technology interaction with your browser/Devices and cookies and other similar technologies tracking the pages you visit, and your mouse movements, clicks and keystrokes, the marketing messages you open and the links you follow, including your interactions with social media |
To enhance your online shopping experience, including as a way to recognize you and welcome you to the Sites, to provide you with customized Sites content, targeted offers, promotions and advertising on the Sites, through other third party sites or app, via email, text messages, or push notifications that are offered by Intelligentsia or other marketing partners that might be of interest to you |
Our Affiliates; third party vendors and other service providers that perform website analytic services for us |
|
COMMUNICATIONS: communications we have with you. Please note that we record calls to our customer service team and communications that occur on the chat feature on our website |
From you |
To handle your requests, to contact you when necessary or requested, including responding to your questions and comments and providing customer support, and to obtain customer feedback and improve our customer service and customer shopping experience |
Our Affiliates; service providers who assist us with customer service, including technology providers for our chat and other functions |
|
IN-STORE PRIVACY: CCTV images of you in and around entrances and exits to our stores and offices, and your customer journey around our store |
From you, our CCTV |
To keep you, other customers, our staff, buildings, systems and data safe and secure, to investigate potential theft, fraud or misconduct |
Our Affiliates; service providers who help us with fraud protection, law enforcement and other governmental authorities in accordance with applicable law. |
|
DEVICE INFORMATION: IP address, internet provider, operating system and browser used, type of device, such as laptop or smart phone, device cookie settings and other device details, such as MAC address and geolocation, if you use our Sites and permit it to obtain your precise geolocation. Your device's settings determine whether geolocation information is provided to us. |
From you and from our Sites technology’s interaction with your browser or Devices |
To make sure our Sites, including app technology, works properly with your Device and make sure you can see and use our intended website and apps on the Device you are using, and for analytical and demographic purposes and to provide offers that may be of interest to you |
Our Affiliates; service providers who help us with fraud protection, and third-party vendors and other service providers that perform website analytic or advertising services for us |
|
USAGE DATA: when you use the Sites, some data is automatically transferred from your browser to our server, including your browser type, operating system type or mobile device model, viewed webpages, links that are clicked, IP address, mobile device identifier or other unique identifier, sites or apps visited before coming to our Sites, the amount of time you spend viewing or using the Sites, the number of times you return, or other click-stream or site usage data, emails we send that you open, forward, or click through to our Sites |
From you and from Sites technology’s interaction with your browser or devices, for more information see “Automated Collection and Use of Information” below |
We will use this information in an aggregated non-specific format for analytical and demographic purposes. |
Our Affiliates; third party vendors and other service providers that perform website analytic or advertising services for us |
|
ACCIDENT INFORMATION: details about any accident or injury on our premises, or health incident |
From you, witnesses or observed about you |
To get you the help you need, deal with the emergency services, insurance and claims |
Law enforcement and other governmental authorities in accordance with applicable law, and our professional advisors. |
|
SUSPECTED CRIME INFORMATION: details of your identity, image, name and address, suspected or alleged thefts, fraud, assault or other criminal behavior |
From crime and fraud prevention agencies, from you, witnesses, and from the police |
To protect customers, the public and our business against risks and crime |
Law enforcement and other governmental authorities in accordance with applicable law, and our professional advisors. |
When we collect certain personal information, such as your account login information, credit card information, or precise geolocation data, we are deemed to be collecting personal information that is “sensitive” under certain state privacy laws. Intelligentsia does not use or disclose sensitive personal information, as defined in applicable laws, for any purposes other than those described above and those permitted by applicable law.
In some jurisdictions, individuals may have the right to provide opt-in consent or withdraw consent for certain uses, including those described above. If you reside in such jurisdictions, you may have additional rights which are detailed below, in the section titled “Your Choices and Your Privacy Rights.”
Intelligentsia may disclose personal information described above in the event we sell or transfer all of a portion of our business or assets.
Please note that if you voluntarily submit any personal information for posting on the Sites, such as a review or blog post, the information may become publicly available and can be collected and used by others, so you should use care before posting information about yourself online.
COMBINED INFORMATION
We also may combine information we collect about you with other information we receive from additional sources. You may choose not to provide us with all of the information we request. In some cases, choosing not to provide information may prevent you from taking full advantage of our Sites’ features.
SOCIAL MEDIA AND USER-GENERATED CONTENT
Intelligentsia website allows you to share product reviews with us. Please use this feature responsibly. We monitor reviews to make sure that only appropriate content is shared through our Sites. Please review our Terms and Conditions of Use for additional information about your responsibilities when posting product reviews.
We also maintain a social media presence, such as a Intelligentsia Facebook page and Intelligentsia Twitter feed. You can interact with us through social media, such as by entering our contests, posting content, sharing material from Intelligentsia websites, and using our social media plug-ins. When you interact with us using social media we may receive information such as your user ID, your profile picture, photos you post, and similar information, which is often determined by your privacy settings at social media sites. We may use the information for the same types of purposes we describe throughout this Privacy Policy. Your use of social media sites is primarily governed by the site operators’ privacy policies and terms of service, and the information you share with us and with others is largely controlled by the privacy settings you have established at those sites.
AUTOMATED COLLECTION AND USE OF INFORMATION
As referenced above, we receive or collect some information automatically when you visit our Sites or engage with other online content we provide. For example, we receive the IP address or other identifier for the computer or other device you use to access our Sites, which may reveal your general geographic location. We collect or receive other information using technology features such as:
Cookies. A cookie is a file saved to your computer or device that may be used to recognize our users when they return to our Sites, provide shopping cart reminders, collect usage information, remember user’s preferences, and provide customized versions of our Sites. We use this information to evaluate our web traffic, enhance our communications, understand the effectiveness of our ad or promotional campaigns, and improve our website and services, including providing you with interest-based ads. For more information on our advertising, see below: “Interest-Based Advertising.” For more information on your choices regarding cookies, see the “Your Choices” section below.
Other Tracking Tools. Our Sites may use web beacons, pixels, JavaScript, or other electronic markers that monitor some types of use. These tools may provide us and our partners with information such as the IP address of the computer or other device you used to access our Sites and how you use the Sites. We use this information to understand patterns of activity on our Sites, to improve features, and to customize our presentation of content to our users, including our advertising. We may work with service providers that help us track, collect and analyze this information. More information on how you can opt-out is included below.
We use Google Analytics including Google Signals, which allows Google to collect session data from our Sites and associate the data with certain users who have signed in to their Google accounts. Google Analytics helps us understand how users engage with our Sites and enable advertising. Our Sites may automatically collect and share your information with Google in connection with these tools. For more information, please review How Google uses cookies. You may also opt-out by using the Google Analytics Opt-out Browser Add-on. Further information is included below under Interest-Based Advertising.
Hotjar. We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site. You can opt-out of Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.
Interest-Based Advertising. We provide interest-based advertising about our products and services on other parties’ websites. We may use third-party advertising companies that use tracking technologies to serve our advertisements across the Internet. These companies may collect information about your visits to the Sites and other websites and your interaction with our advertising and other communications. These advertising companies serve ads on behalf of us and others on non-affiliated sites, and some of those ads may be personalized, meaning that they are intended to be relevant to you based on information collected about your visits to the Sites and elsewhere over time. Other companies may also use such technology to advertise on our Sites. You have the choice to tell us not to collect and use this information, and in some jurisdictions, we will only engage in interest-based advertising if you opt-in.
If you would like more information about advertising and to know your choices concerning tracking tools and interest-based ads, visit:
http://www.networkadvertising.org/choices/
http://www.aboutads.info/choices
In Canada, please visit: http://youradchoices.ca/choices/
In the EU, please visit: http://www.youronlinechoices.eu/
Intelligentsia may develop content and advertising based on the analytics and user information developed from cookies or similar technology. For more information on your choices regarding advertising, see the “Your Choices” section below.
Referrer Headers. We may record referrer headers when you follow links to our Sites, which may be sent to us automatically by your web browser. In these cases, we may receive information such as the URL of the website that referred you to our Sites, or search queries you used to find our Sites. We use this information to understand our web traffic, to improve our services, to increase their accessibility to search engines and others, and to monitor our advertising campaigns.
YOUR CHOICES AND YOUR PRIVACY RIGHTS
We offer you certain choices about the information we collect, how we use and share information, and how we communicate with you. To help protect your privacy, when you exercise these choices we may take reasonable steps to verify your identity, such as requiring a password.
Opt-out Choices
If you do not wish to receive communications from us about special offers and promotions, you can opt-out of receiving these communications by following the instructions contained in the messages you receive. Even if you opt-out of receiving these messages, we reserve the right to send you certain communications relating to the services we provide, and we may send you service announcements and administrative messages. We do not offer you the opportunity to opt-out of receiving those communications.
By contacting us as shown in the “Contact Us” section of this Policy, you may opt-out of receiving communications from us, such as newsletters and surveys. You also have the following specific opt-out choices:
- Cookies. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. However, rejecting cookies may affect your user experience, and you may not be able to access or use certain features of our Sites. In addition, disabling cookies may invalidate opt-outs that rely on cookies, such as web analytics or targeted advertising opt-outs. Because Intelligentsia does not own or control browser tools, we cannot guarantee their effectiveness.
- Opt-Out Preference Signals: We are working towards enabling Global Privacy Control (GPC) as an additional way for you to submit a request to opt-out of the sale and sharing of your personal information through browsers and/or browser extensions that support such a signal. Until then, you can opt-out of the use of third-party cookies for personalized advertising by setting your cookie preferences on our website (see above, Automated Collection and Use of Your Information—Interest-Based Advertising) or on your browser.
- Mobile devices and geographic location. When you use our website on your mobile device, you may choose not to share your location with us by adjusting the device’s location services settings. For instructions on changing the relevant settings, please contact your plan provider or device manufacturer. For more information on opting out on mobile devices, you may also visit: http://www.networkadvertising.org/mobile-choices
- Google Analytics. We may use Google Analytics to monitor activity and performance of the Sites. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at http://www.google.com/policies/privacy/partners.
Access, Correction, & Deletion
We respect your right to access, correct, and delete your personal information. You may access your personal information by signing into your account. From there, you can correct or modify your information. You may also exercise your rights, subject to applicable laws, to request that we delete or restrict access to your personal data. We may need to retain it for legally permitted purposes and this will be explained to you if necessary.
If you need assistance correcting or updating your personal information, or would like to request that we delete your personal information, please contact us using the contact information detailed in the “Contact Us” section below.
Your Privacy Choices
Depending on where you live, you may contact us to request information about circumstances in which we share certain personal information with third parties for their marketing purposes and allow third parties to collect such information from our Sites. To request information please contact us as indicated in the “Contact Us” section of this Policy.
Depending on where you live, state privacy law provides you with the following rights with respect to your personal information:
- The right to request that we do not sell or share your personal information and the right to opt out of the processing of your personal information for purposes of targeted advertising and/or profiling in furtherance of decisions that produce legal or similarly significant effects - Do Not Sell or Share My Personal Information
- The right to limit the use of your sensitive information - Limit the Use of My Sensitive Information.
- The right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing. To submit a request for correction, you may call us at (888) 945-9786 or visit https://www.intelligentsiacoffee.com/contact
- The right to know what personal information we have collected, used, disclosed, and sold about you. To submit a request to know the categories of personal information we have collected or the specific pieces of information we have collected, or
to obtain a copy of the personal information we have collected in a portable and, to the extent technically feasible, readily usable format,
you may call us at (888) 945-9786 or visit https://www.intelligentsiacoffee.com/contact
- The right to request that we delete any personal information we have collected about you. To submit a request for deletion, you may call us at (888) 945-9786 or visit https://www.intelligentsiacoffee.com/contact
- The right to appeal a request that is rejected. To make such an appeal, you may call us at (888) 945-9786 or visit https://www.intelligentsiacoffee.com/contact
Depending on where you live, you may have the right to designate an authorized agent to make a request on your behalf. When you exercise these rights and submit a request to us, we will verify your identity by asking for information about your relationship with Intelligentsia, such as email address on file, loyalty/customer number, recent order number, or the last four digits of your credit or debit card. We may also use a third-party verification provider to verify your identity. We will endeavor to honor such requests unless such a request conflicts with certain lawful exemptions under applicable law.
Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.
In addition, applicable law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have “sold” or “shared” about you. For the 12-month period prior to the date of this Privacy Policy, Intelligentsia has not sold any personal information about its customers. For the 12-month period prior to the date of this Privacy Policy, Intelligentsia has only shared personal information about its customers for purposes of targeted advertising (as that term “shared” is defined in applicable law) as described above.
RETENTION OF PERSONAL INFORMATION
We retain personal information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we will refer to the following criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data.
- Whether the data is necessary to provide our products, services or programs.
- Whether our visitors have the ability to access and delete the data within their accounts.
- Whether our visitors would reasonably expect that we would retain the data until they remove it or until their Intelligentsia Coffee accounts are closed or terminated.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
CHILDREN’S PRIVACY
Intelligentsia Sites are not directed at children under the age of 13 and Intelligentsia does not knowingly solicit or collect personal information from children under 13 without prior verifiable parental consent. If Intelligentsia learns that a child under the age of 13 has submitted personal information to us without parental consent, we will take all reasonable measures to delete such information from our databases and/or to not use such information for any purpose (except as necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from a child under 13, please contact us.
RIGHT TO REMOVAL OF POSTED INFORMATION—MINORS
If you are a minor and have a registered account with Intelligentsia, you have the right to request removal of unwanted information that you publicly post on our Sites through customer reviews or other methods. To request removal of such information, you can contact Intelligentsia at the phone number or postal address below. Upon receiving such a request, Intelligentsia will make sure that the information is not publicly available on our Sites, but the information may not be completely or comprehensively removed from Intelligentsia systems. Intelligentsia does not have actual knowledge about selling or sharing personal information of consumers under the age of 16.
VISITORS FROM OUTSIDE THE UNITED STATES—CROSS-BORDER TRANSFER
The Sites are operated in the United States. If you are visiting the Sites from outside the United States, your information may be transferred to, stored and processed in the United States or other countries in accordance with this Privacy Policy. The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Sites and/or providing personal information to us, you consent to transfer of your information to our facilities as described in this Privacy Policy.
RIGHT TO APPEAL OR LODGE COMPLAINTS
We are transparent about the ways in which we collect and use personal information and welcome your questions and concerns. Depending on where you live, you may have the right to appeal our decision regarding your privacy rights. If you would like to appeal any decision regarding your privacy rights or have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see HTTPS://WWW.FTC.GOV/FAQ/CONSUMER-PROTECTION/SUBMIT-CONSUMER-COMPLAINT-FTC. Within the United Kingdom, you may obtain more information about how to protect your rights and lodge a complaint by contacting the UK Information Commissioner’s Office, see HTTPS://WWW.GOV.UK/DATA-PROTECTION/MAKE-A-COMPLAINT.
DO NOT TRACK DISCLOSURE
Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt-out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals and therefore, Intelligentsia does not recognize DNT. For more information regarding your choices regarding tracking, see the “Your Choices” section, above.
INFORMATION SECURITY
The nature of our business requires us to collect and maintain certain personal information, and we understand that we have a responsibility to protect it. To do so, we maintain appropriate administrative, physical, and technical safeguards that are designed to safeguard your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Your Intelligentsia account is protected by your log-in credentials, which you must keep secure and confidential. We also use the Hypertext Transfer Protocol Secure (HTTPS) communications protocol in many areas of the site where we ask users to submit information.
Intelligentsia endeavors to maintain accurate information and provide you with options to update your information. You can log into your account and modify your information using your log-in credentials. You also may request that we update your information by contacting us as described in the “Contact Us” section of this Policy.
LINKS TO OTHER SITES
We may provide links to other websites for your convenience and information. Since these sites are not owned, controlled, or operated by Intelligentsia, we cannot control how information collected by these linked sites will be used, shared, or secured. If you visit linked sites, we strongly suggest that you review the privacy notices or policies posted at those sites. We are not responsible for the content of linked sites, your use of them, or the information practices of their operators.
CONTACT US
If you have any questions or concerns regarding this Privacy Policy or how we collect and use the information of our customers, please contact us at:
Intelligentsia coffee, inc., 1850 W. Fulton Street, Chicago, IL 60612; Attn: Privacy Request;
http://www.intelligentsiacoffee.com/contact;
Emailing your request to Intelligentsia’s Customer Service Team at customersupport@intelligentsiacoffee.com; or
Calling 1-888-945-9786
CUSTOMER SERVICE
(888) 945-9786 Monday through Friday, 6 A.M. – 6 P.M. CT
If we need, or are required, to contact you concerning any event that involves your information, we may do so by email, telephone, or mail.
UPDATES TO OUR PRIVACY POLICY
As we modify our information collection or privacy practices, and as privacy laws evolve, it may be necessary to revise or update this Policy. We will always keep the current version of our Privacy Policy posted on the Sites and will change the effective date to reflect when it was last revised. If we change the policy in a material and retroactive manner, we will provide appropriate notice to you. We will continue to protect your personal information in accordance with applicable law and as described by our current Privacy Policy.