Privacy Policy

Privacy Policy

Last Updated: December 17, 2019.

1. Applicability and Scope

This privacy policy ("Privacy Policy") is applicable to Biz2Credit Inc. and its subsidiaries (collectively, "Biz2Credit" "we" or "us"). At Biz2Credit, we consider the privacy of our clients, customers and users of our website and services (collectively, "Users" or "you") to be extremely important. In this document, we describe how Biz2Credit collects, uses and discloses the information we collect from you and about you when you browse our website ("Website") or use our finance products and online services ("Services").

  • Types of information collected
  • Method of collecting information
  • Purpose for which information is collected
  • Uses of information collected
  • Sharing of collected information
  • Storage and protection of collected information Users choices regarding information collection
  • Children's privacy rights
  • Links to other websites and services
  • Contact information
  • Changes to Privacy Policy

Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use.

2. Types of Information Collected

In connection with your use of our Website and Services, we collect the following types of information:

Personally Identifiable Information ("PII") refers to any information that identifies or can reasonably be used to identify, contact, or locate the person to whom such information pertains, including, but not limited to, name, address, phone number, fax number, email address, financial profiles, social security number, FICO scores, and credit card information. PII does not include information that is collected anonymously (that is, without identification of the individual user) or demographic information not connected or reasonably connectable to an identified individual. In this Privacy Policy the term PII may be used to specifically identify an individual business owner, principal, business representatives, loan applicants, or Website visitors.

In the U.S., federal law requires Biz2Credit to collect and verify beneficial ownership information of our Customers. In addition, if you make payments through the Services, Biz2Credit may also collect information, such as payments or invoicing information including name, postal and email addresses, or phone number. Certain information may not be personally identifiable when standing alone but may become so when combined with other information. As a rule, Biz2Credit does not collect PII when you visit our Website, unless you choose to provide such information or use Services that necessitate the need to collect that information.

Computer and other Technical Information When you use our Website, we automatically collect information relating to your computer, mobile device and other information associated with the device you use to access the Services, including: download, use and access information for mobile applications or mobile-optimized sites; IP address or other unique identifiers that are automatically assigned to your computer, mobile or other device used to access the Website; the type of browser you are using; the third party website from which your visit originated; the operating system you are using; the domain name of your Internet service provider; the search terms you use on our Website; the specific areas within our Website or Service that you visit; and/or the time of day and duration of your visits, internet connection, referring/exit pages, clickstream data, and information that you search for using the Services. This information can be used to identify you and is considered PII.

Business Information means information regarding businesses and their principals that use or otherwise access the Services, including: business name, address, email, and telephone number, company structure, industry type, incorporation date, annual revenue, bank account information, marketplace account information, payment information, business social network data, accounting information, vendor usage information, information regarding our transactions and experiences with the business, information regarding business principals and beneficial ownership information (collectively, "Business Information"). Business Information may also include information about your customers if collected in connection with your use or access of the Services. Use of our Business Finance Services is governed by our Terms of Use and Business Finance Terms and Conditions.

3. Methods of Collecting your Information

The information we collect about you depends on how you use our Services, and if your business becomes an enterprise customer.

Information Provided by You. We may collect information from you when you register or use the Services. For example, we may collect PII, user information and Business Information from you when you register an account on the Sites, fill out forms or fields on the Sites, or complete an application for a product or service available through the Services. We may also collect any information when you communicate with us through email, mail, text, telephone, facsimile or other means.

Information Collected when You Use Services. As noted above, we automatically collect PII from your computer, mobile device or other PII associated with device you use to access the Services (including downloading and using a mobile application or accessing a mobile optimized Site). We may collect PII when you view content about the Services on a third-party website or open emails or links in email communications from us. We, our business partners, or our service providers may use cookies, web beacons, pixel tags, and other similar technologies which collect information when we provide you with Services.

IP Address. An IP address is a number that is assigned to your computer, mobile or other computing device whenever you are surfing the Internet. Web servers (computers that "serve up" web pages) automatically identify your computer or other computing device by its IP address. When users request pages from our Website, servers may log their IP addresses. Biz2Credit may collect IP addresses for the following purposes, among others: system administration, to report non-personal aggregate information, and to track the use of the Website. IP addressed associated with your computing devices, mobile phones, or other devices are PII.

Cookies. Cookies are small text files containing a string of alphanumeric characters. When you visit the Service, we or our analytics providers may send one or more cookies - a small text file containing a string of alphanumeric characters - to your computer that uniquely identifies your browser and lets Biz2Credit help you log in faster and enhance your navigation through the site.

We may use both session cookies and persistent cookies.

Session Cookies: A session cookie disappears after you close your browser.

Persistent Cookies: A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser and may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser's directions.

Your Cookie Choices: You can reset your web browser to refuse all cookies or to choose when a cookie is permitted. Please review your web browser "Help" file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize all the features of the Services to their fullest potential.

Clear GIFs, Pixel Tags, and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Local Storage Objects. We may use Flash Local Storage Objects ("Flash LSOs") to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose "Global Storage Settings Panel," and follow the instructions. To see the Flash LSOs currently on your computer, choose "website Storage Settings Panel" and follow the instructions to review and, if you choose, to delete any specific Flash LSO.

Log file information. Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include information such as your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

Location data. If you choose to allow us access your location data when you access the Services, we may access, collect, monitor and/or remotely store "location data," that may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to us information about how you browse or use the Service. Some features of the Service, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.

Email Communications. If you send us an email with questions or comments, we may use PII to respond to your questions or comments and save your questions or comments for future reference. For security reasons, it’s not recommended that you send non-public personal information to Biz2Credit by email. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive promotional messages, you will be given the option to opt-out. We also use your information to send you Service-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related e-mails.

Information Received from Third Parties. The Services allow us, upon your direction, to obtain user information and Business Information from third party entities that your business maintains accounts with such as financial institutions, service providers referral partners, identity verification services, card networks, vendors, mailing list providers, consumer reporting agencies, commercial credit bureaus and associations, fraud prevention agencies, and publicly available sources including social networking services. We may combine this information with information we already collected from you or about you. For example, we may obtain transactional information about your business from financial institutions, information about your business’s engagement with customers from social networking services, and information about your business’s sales volume from service providers.

4. Use of Information

Marketing and Advertising, Third-Party Ad Networks and Online Tracking. We, advertisers, sponsors, and our third-party service providers may use third parties such as network advertisers to display advertisements on our Site. Network advertisers are third parties that display advertisements based on your visits to our Site as well as other websites. We, advertisers, our third-party service providers, and the ad networks may track your behavior on this Site. Specifically, third-party ad-network providers (such as Google or Facebook), advertisers, sponsors, and/or traffic-measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one.

Use of Personal Information; Opt Out Rights. In order to generate such targeted advertisements, we may provide these third-party advertisers with certain information about your usage of our Site and our Services, as well as aggregate or non-personally identifiable information about visitors to our Site and users of our Service. This information typically includes the following PII: IP address, email address, phone number, mailing address (if applicable), name and company name. Upon uploading, the ad server companies immediately "hash" this PII data so that it is not human-readable, for added security. If this data set matches information the ad server company already has on file for you, these third-party companies may use this information to re-target you with ads we think may be of interest to you using "cookies". However, we are never compensated for the transfer of any of your PII to any third party (including third-party ad-network providers). The ad server networks we use (EG, Google and Facebook) have confirmed they will delete and not make any further use of any customer data sent to them as soon as this is "matched" with their data set. In addition, we offer our customers and users the right to opt out of receiving future advertisements using our products in accordance with applicable law, as per instructions set forth in the targeted advertisements.

Automated Devices; Privacy Practices. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site, and to the extent permitted, our Apps. We also may use other analytic means to evaluate our Site and Apps. We use these tools to help us improve our Site’s and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Cross-Device Use. We and our service providers, including Google, may use the information that we collect about you (whether directly from our Site, from our mobile applications, through your device(s), or from a third party) to help us and our service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We and our service providers also may use the cross-device use and other information we learn about you to serve targeted advertising on your devices and to send you emails. To opt-out of cross-device advertising, you may follow the instructions set forth below. Please note: if you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt-out each browser or device that you use.

Ad Network Opt-Out Rights. You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information regarding this practice by NAI members and DAA members, and your choices regarding the use of this information used by these companies, including how to opt out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA).

Opting out of one or more NAI member or DAA member networks (many of which will be the same) means only that those members no longer will deliver targeted content or ads to you. It does not mean that you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements based, for example, on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit the opt-out page, or if you subsequently erase your cookies, use a different computer, or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites, accessible by the links above.

Other Uses of Information. We use information collect about you for other purposes relating to or to enhance our provision of Services to you, including to:

  • Provide, operate, maintain and improve the Services
  • Enable you to access and use the Services
  • Send you technical notices, updates, security alerts and administrative messages
  • Enhance the customer registration and application process
  • Provide customer support services
  • Conduct surveys and collect feedback about the Services
  • Monitor and analyze trends, usage and other metrics relating to the Services, including aggregate metrics such as total number of visitors, traffic, and demographic patterns
  • Notify you about special offers and other products and services and related marketing and adverting purposes (as more fully described above)
  • Diagnose or fix technology problems and other security-related purposes
  • Manage and protect our Website and IT infrastructure
  • Detect and protect against potentially prohibited or illegal activities, including fraud, unauthorized access and intellectual property infringement
  • Respond to lawful requests for information or legal process, or establish, exercise, or defend a legal claim
  • Comply with our contractual obligations, our policies, industry standards, and applicable laws
  • Process and use your information in an anonymized or aggregated form for scorecarding, marketing and other data analytics purposes
  • Use for other purposes for which we provide notice to you at the time of collection or for which we obtain your consent

5. Sharing of Your Information

We will not rent or sell your information to third parties outside Biz2Credit and its group of affiliated companies (including any parent, subsidiaries and affiliates) without your consent, except as noted below:

Sharing with Third Parties. We may share your information with third-party business partners for the purpose of providing the Service to you. Those business partners will be given limited access to your information as is reasonably necessary to deliver the Service. By providing Biz2Credit your Information and Documents, you expressly authorize (a) Biz2Credit to disclose any or all of such Information and Documents to any bank, financial institution, factor, company providing merchant cash advances or receivables financing or other business funding, or other Funder (collectively, "Funder") and/or other third parties that may be involved in the provision of commercial fundings, merchant cash advances or other business funding products (collectively, "Funder Parties") and (b) each Funder to disclose any or all of such Information and Documents, and share any or all of such Information and Documents with other Funder Parties in connection with such potential transactions. Customer understands and agrees that Funders may share and/or retain Information and Documents and any other information provided by Biz2Credit or received by them, whether or not Customer qualifies for a funding or other funding product and whether or not Customer enters into a credit or other transaction. Customer further agrees to notify any Funders directly if Customer no longer wants to receive communications from any Funder. By providing Biz2Credit your email address and/or phone number, you consent to our using the email address and/or phone number to send you Service-related notices, including any notices required by law, in lieu of communication by postal mail. We may also use your email address and/or phone number to send you other messages, such as changes to features of the Service. We may also share your information with our funding subsidiary Itria Ventures LLC ("Itria"), if you submit an application for business financing, including additional documents and information if you elect to proceed with Itria for your small business financing.

Business Transformation. We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. The information you provide to us or we collect from you may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.

Pursuant to Lawful Requests. Biz2Credit will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Biz2Credit, our Users or others.

Use of Aggregate or Pseudonymous Information. We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

6. How We Store Your Information

Your information collected through the Service may be stored and processed in the United States or any other country in which Biz2Credit or its subsidiaries, affiliates or service providers maintain facilities. Biz2Credit may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Biz2Credit or its subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy. Biz2Credit reserves the right to remove any content that contains a virus or other malicious code, or that otherwise violates any term of this Privacy Policy or Terms of Use.

7. Security of Your Information

Biz2Credit cares about the security of your information and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Service. We take reasonable measures, including physical, technical and organizational safeguards to protect your information from unauthorized access, disclosure, misuse, alteration, and destruction. These security measures include physical access controls, firewalls, data encryption and information access authorization controls. You are responsible for any use of the Service on your account, whether by you or a third party, as well as for controlling access to your email communications from us, at all times. However, we cannot ensure or warrant the security of any information you transmit to Biz2Credit or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.

For site security purposes and to ensure that our Website remains available to all users, we may employ software programs to identify unauthorized attempts to upload or change information, or otherwise cause damage. When you submit information to us through our Website, you should be aware that your information is transmitted across the Internet, and that no method of transmission over the Internet is 100% secure. We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the information under our control. While we strive to protect your privacy, we cannot guarantee or warrant the security of any information you choose to disclose or transmit to us online and are not responsible for the theft, destruction, or inadvertent disclosure of your PII. In the event your PII (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you (including by e-mail) at the last address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation.

8. California Privacy Data Use Disclosure

California law grants California residents’ certain rights and imposes restrictions on particular business practices as set forth below. We are not compensated for the transfer of any of your PII to any third party (including third-party ad-network providers).

We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used. Please see chart below.

Other Permissible Collections and Uses: We may process your information in an anonymized or aggregated form for purposes other than described in this Privacy Policy. We may use the information we collect for other purposes for which we provide notice to you at the time of collection or for which we obtain your consent.

California Residents’ Rights: California law grants California residents’ certain rights and imposes restrictions on particular business practices as set forth below.

Do-Not-Sell: California residents have the right to opt-out of the sale of their "personal information". We do not sell your personal information to anyone. We do provide certain personal information of customers and users to ad server networks in order to generate targeted ads for our products and services, but we offer such customers and users the right to opt out of receiving future advertisements. Please refer to section 3 above.

Initial Notice:We have listed below the categories of personal information about California residents that we collect and/or disclose to third parties, including service providers. We only collect and disclose your personal for a business purpose relating to our products and services.

CATEGORIES OF PERSONAL INFORMATION Categories of Information we collect Categories of Information we disclose
NAME, CONTACT INFORMATION AND IDENTIFIERS: name, company name, address, email address, account information, social security number, driver’s license number and other similar identifiers. YES YES
CUSTOMER RECORDS: paper and electronic customer and business records that you have uploaded onto our system, including the information specified in Section 1 of this Privacy Policy and in this Chart. YES NO
PROTECTED CLASSIFICATIONS: protected classifications under California or federal law, such as race, sex, age, religion, national origin, sexual orientation, disability, etc. YES NO
purchasehistory and tendencies: commercial information,including products or services purchased or other purchasing or consuming histories or tendencies. YES NO
Biometric information: physiological, biological, genetic or behavioral information. NO NO
USAGE DATA: internet activity information, including browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement. YES NO
GEOLOCATION DATA: Geolocation data, pgeographic location information about a user or device YES YES
AUDIO/VISUAL: audio, electronic, visual or other similar information. YES NO
EMPLOYMENT HISTORY: professional or employment-related information. YES NO
EDUCATION INFORMATION: non- publicly available academic or other educational information. YES NO
PROFILES AND INFERENCES: characteristics used create a profile or reflect a user’s preferences, characteristics, l trends, predispositions, behavior, attitudes, abilities and aptitudes. YES NO

Verifiable Requests for Copy, Deletion and Right to Know. Subject to certain exceptions, California residents have the right to make the following requests, at no charge, up to twice every 12 months:

Right of Deletion: The right to request deletion of their personal information that we have collected about them and to have such personal information deleted, subject to certain exemptions, including where such information is necessary complete the transaction for which the personal information was collected, provide a good or service requested by the customer, or reasonably anticipated within the context of a business’s ongoing business relationship with the customer, or otherwise perform a contract between a business and the customer.

Right to a Copy: The right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.

Right to Know: The right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the categories of personal information collected and the purposes for which such information was collected (in each case as specified in this Privacy Policy).

Shine the Light: California residents may request, free of charge, a list of what personal information (if any) we provided to third parties in the preceding year for that third party’s direct-marketing purposes. You may make one request per calendar year. In your request, please attest that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us as set forth in the User Agreement. Please allow up to thirty (30) days for a response.

Incentives and "Non-Discrimination". The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on financial incentives, including loyalty programs offered to California consumers related to their personal information.

Non-Discrimination: If consumers exercise their rights under CCPA, businesses may not discriminate against them including by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties, unless doing so is reasonably related to the value provided by the consumer’s data.

Submitting Requests. Requests to exercise the right to deletion, right to a copy, and / or the right to know may be submitted by contacting us at 1-800-200-5678 (toll free) or by emailing us at privacy@biz2credit.com.We will respond to verifiable requests received from California consumers as required by law.

9. Protecting Children

We take special care to protect the safety and privacy of children. Any features or aspects of our Website which may require submission of information are not intended for anyone under 18 years of age. Biz2Credit does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to register as Users. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible.

If you believe that we might have any information from or about a child under 18, please contact us at privacy@biz2credit.com

10. Your Choices About Your Information

You control your account information and settings: You can also stop receiving promotional email communications from us, if any, by clicking on the "unsubscribe link" provided in such communications. We make every effort to promptly process all unsubscribe requests. As noted above, you may not opt out of Service-related communications (e.g., account verification, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at privacy@Biz2Credit.com.

Please refer to your mobile device or browser's technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents Biz2Credit or its analytics providers from tracking your browser's activities in relation to the Service. However, doing so may disable many of the features available through the Service. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at privacy@Biz2Credit.com. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser or device at this time. Following termination or deactivation of your User account, Biz2Credit may retain certain information you have provided to us for a commercially reasonable time for backup, archival, or audit purposes.

11. Links to Other Web Sites and Services

We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein or sent to you in a message from any third party that contacts you through use of the Service. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website or through our Service, are subject to that third party's own rules and policies. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service.

12. How to Contact Us

If you have any questions about this Privacy Policy or the Service, please contact us at privacy@Biz2Credit.com Or you can write to us at:

Biz2Credit Inc.
One Penn Plaza, Suite 4350,
New York, NY 10119

13. Changes to Our Privacy Policy

The Privacy Policy is revised on the annual basis to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner, we will let you know and update the 'last modified' date at the bottom of this page. Last Modified: December 17, 2019