Privacy Notice of the Novocure group

Last updated: January 2022

 

General Data

We may process general personal data about you.

Financial Data

We may process your financial data.

Health Data

We may process your health data.

[Note: concerns Section 3: all categories of data]. [Note: concerns Section 3: communication data, business relationship data, contract data]. [Note: concerns Section 3: communication data, business relationship data, contract data, other data].

Location Data

We may process your location data.

Biometric Data

We may process your biometric data.

Intimate Data

We may process intimate data about you.

[Note: concerns Section 3: behavioral and preference data]. [Note: concerns Section 3: registration data, business relationship data, contract data]. [Note: concerns section 3: other data].

Provided Data

We may process personal data that you provide to us.

Collected Data

We may process personal data that we collect about you.

Received Data

We may process personal data about you that we receive from third parties.

[Notes: concerns Section 3: especially penultimate paragraph]. [Note: concerns Section 3: especially last paragraph]. [Note: concerns Section 3, especially last paragraph].

Marketing

We may use your personal data for marketing and advertising.

Product Development

We may use your personal data for the development and improvement of products and services.

Other Purposes

We may use your personal data for other purposes without direct connection with the core service.

[Note: concerns Section 4: marketing purposes and relationship management (para. 4)]. [Note: concerns Section 4: market research, to improve our services and operations, and for product development (para. 5)]. [Note: concerns Section 4: security purposes, etc. (para. 6 ff.)].
 

Data Transfers

We transfer your personal data to other companies that decide themselves how to use the data.

 

Worldwide

We also process your personal data outside of Switzerland and the EU.

1.  What is this Privacy Notice about?

The Novocure group (also «we», «us») collects and processes personal data that concern you but also other individuals («third parties»). We use the word «data» here interchangeably with «personal data».

 

In this Privacy Notice, we describe what we do with your data when you use https://www.novocure.com/ and our other websites and apps (collectively «website»), obtain services or products from us, interact with us in relation to a contract, communicate with us or otherwise deal with us. When appropriate we will provide a just-in-time notice to cover any additional processing activities not mentioned in this Privacy Notice. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, other privacy notices, forms and notices. In some circumstances, our use of your data will be subject to the requirements of the Health Information Portability and Accountability Act (commonly known as «HIPAA»). For example, this is the case in some situations when you enroll in one of our clinical trials, or if you are a United States citizen who is treated with a Novocure product. In those circumstances, our HIPAA Privacy Notice available at https://www.novocure.com/privacy-policy/ will also apply. Additionally, in some cases our use of your data may be subject to the California Consumer Privacy Act («CCPA»). In those cases, our California Consumer Privacy Notice available at https://www.novocure.com/california-consumer-privacy-notice/  will also apply. If you have questions about which policy applies to the information you have submitted, please do not hesitate to contact us. You will find our contact details in Section 2.

If you disclose data to us or share data with us about other individuals, such as family members, close personal friends, healthcare professionals, etc., we assume that you are authorized to do so and that the relevant data is accurate. When you share data about others with us, you confirm that. Please make sure that these individuals have been informed about this Privacy Notice.

This Privacy Notice is aligned with the EU General Data Protection Regulation («GDPR»), the Swiss Data Protection Act («DPA») and the revised Swiss Data Protection Act («revDPA»). However, the application of these laws depends on each individual case.

2.  Who is the controller for processing your data?

The Novocure GmbH, Park 6, CH-6039 Root D4 (the «Novocure GmbH») is the controller for the Novocure group’s processing under this Privacy Notice, unless we tell you otherwise in an individual case, for example in additional privacy notices, on a form or in a contract. However, unless we tell you otherwise, this Privacy Notice also applies where a group company of the Novocure group is the controller, instead of the Novocure GmbH. This applies, in particular, where your data is processed by a group company in the context of its own legal obligations or contracts with such a group company, where data is exchanged with a group company, or where you otherwise interact with a group company. In these cases, the group company is the controller, and only if it starts sharing your data with other group companies for their own purposes (see Section 6), will they become controllers of their own.

 

You may contact us for data protection concerns and to exercise your rights under Section 10 as follows:

Novocure GmbH
Park 6
CH-6039 Root D4
dataprotection@novocure.com

We have appointed the following additional positions:

  • Data Protection Officer according to articles 37 et seq. GDPR:

Dr. Christian Schafer,
Active Assets A2 GmbH
Gottlieb-Daimler-Str. 5
78467 Konstanz, Germany
info@active-assets.com

  • Data Protection Representative in the EU according to article 27 GDPR:

Novocure GmbH
Elektrastr. 6
81925 Munich, Germany
dataprotection@novocure.com

You can also contact these parties for privacy concerns.

3.  What data do we process?

We process various categories of data about you, including current but also previous versions where information changes over time. The main categories of data are the following:

Technical data: When you use our website or other online offerings, we collect the IP address of your terminal device and other technical data in order to ensure the functionality and security of these offerings. This data includes logs with records of the use of our systems. We generally keep technical data for 6 months. In order to ensure the functionality of these offerings, we may also assign an individual code to you or your terminal device (for example as a cookie, see Section 11). Technical data as such does not permit us to draw conclusions about your identity. However, technical data may be linked with other categories of data (and potentially with your person) in relation to user accounts, registrations, access controls or the performance of a contract.

 

Registration data: Certain offerings and services, such as free WLAN access, newsletters, etc., can only be used with a user account or registration. In this regard you must provide us with certain data, and we collect data about the use of the offering or If we or our contractual partners issue vouchers or invitations for events, we may require certain data when you redeem them, which we share with the issuing contractual partner (see Section 6). Registration data may be required in relation to access control systems, potentially including biometric data, depending on the control system. We generally keep this information for 12 months from the date use of the service ceases or the user account is closed.

 

Communication data: When you are in contact with us via the contact form, by e-mail, telephone, or other means of communication, we collect the data exchanged between you and us, including your contact details and the metadata of the communication. If we have to determine your identity, for example in relation to a request for information, a request for press access, etc., we collect data to identify you (for example a copy of your passport or ID). We generally keep this data for 12 months from the last exchange between us. This period may be longer where required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. E-mails in personal mailboxes and written correspondence are generally kept for at least 10 years.

 

Business Relationship Data: With business relationship data we mean the basic data that we need about you, in addition to contract data (see below), for the performance of our contractual and other business relationships or for marketing purposes, such as name and contact details, and information about, for example, your role and function, your bank details, your date of birth, treatment history, legal representatives, signature authorizations and declarations of consent. We process your business relationship data if you are a patient, caregiver, vendor, supplier, healthcare provider, or other business contact, or if you work for one of these companies (for example as a contact person of the business partner), or because we wish to contact you for our own purposes or for the purposes of a contractual partner (for example in the context of marketing and advertising, invitations to events or clinical trials, newsletters, etc.). We receive business relationship data from you (for example when you sign a contract with us), from parties you work for, or from third parties (such as contractual partners, associations), and from public sources (such as public registers or the internet). We also process health data and information about third parties as part of business relationship data. We may also collect business relationship data from our shareholders and investors. We generally keep business relationship data for 10 years from the last exchange between us or from the end of the contract. This period may be longer if required for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons. For contacts used only for marketing and advertising, the retention period is in principle much shorter, usually no more than 2 years from the last contact.

Patient health data: If you are a patient, we collect information about your health condition, health insurance coverage and healthcare provider. This includes health data and information about third parties, for example about your healthcare provider or caregiver. We receive this data primarily from you, but also from third parties, such as your healthcare provider. We generally keep this data for 5 years from the end of your treatment or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.

 

Contract data: This means data that is collected in relation to the conclusion or performance of a contract, for example information about the contracts and the services provided or to be provided, as well as data from the period leading up to the conclusion of a contract, information required or used for performing a contract, and information about This may include health data and information about third parties, for example about hereditary diseases in a family. We generally collect this data from you, from contractual partners and from third parties involved in the performance of the contract, but also from third-party sources (for example credit information providers) and from public sources. We generally keep this data for 10 years from the last contract activity or from the end of the contract. This period may be longer where necessary for evidentiary purposes, to comply with legal or contractual requirements, or for technical reasons.

 

Other data: We also collect data from you in other situations. For example, data that may relate to you and is processed in relation to administrative or judicial proceedings. We may also collect data for health protection reasons (for example as part of our health protection concept) and clinical research. We may obtain or create photos, videos and sound recordings in which you may be identifiable (for example for our press releases or with our security cameras) for which we may seek additional consent. We may also collect data about who enters certain buildings and when, or who has access rights (including in relation to access controls, based on registration data or visitor lists, etc.), who participates in events or clinical trials, and who uses our infrastructure and systems and Moreover, we collect and process data about our shareholders and other investors, in addition to business relationship data, including information for registers, in connection with the exercise of their rights and events (for example general meetings). The retention period for this data depends on the processing purpose and is limited to what is necessary. This ranges from a few days for many security cameras, to a few weeks for contact tracing and visitor data, which is typically kept for 3 months, to several years or more for reports about clinical trials and events with images. Data relating to you as a shareholder or investor is kept in accordance with corporate law, but in any case for as long as you are invested.

Much of the data set out in this Section 3 is provided to us by you (through forms, when you communicate with us, in the context of the conclusion of a contract, when you use the website, etc.). You are not obliged or required to provide us with data, except in certain cases, for example within the framework of binding health protection concepts (legal obligations). If you wish to enter into contracts with us or use our services, you must also provide us with certain data, in particular business relationship data, contract data and registration data, as part of your contractual obligation so that we can perform the contract accordingly. When using our website, the processing of technical data cannot be avoided. If you wish to gain access to certain systems or buildings, you must also provide us with registration data.

 

As far as it is not unlawful we also collect data from public sources or receive data from other companies within our group, from public authorities and from other third parties.

4.  For what purposes do we process your data?

We process your data for the purposes explained below. Further information is set out in Sections 11 and 12 for online services. These purposes and their objectives represent interests of us and potentially of third parties. You can find further information on the legal basis of our processing in Section 5.

We process your data for the purposes of providing our products, devices and ongoing therapy. For this purpose, we use in particular communication data, business relationship data, contractual data and patient health data.

 

We process your data for purposes related to communication with you, in particular in relation to responding to inquiries and the exercise of your rights (Section 10) and to enable us to contact you in case of queries. For this purpose, we use in particular communication data, business relationship data, and registration data in relation to offers and services that you use. We keep this data to document our communication with you, for training purposes, for quality assurance and for follow-up inquiries.

 

We process data for the conclusion, administration and performance of contractual relationships.

 

We process data for marketing and advertising purposes and relationship management, for example to send patients, customers, and other contractual partners personalized advertising for products and services from us and from third parties. This may happen in the form of newsletters and other regular contacts (by e-mail or telephone), through other channels for which we have contact information from you, but also as part of marketing campaigns (for example events, etc.) and may also include free services (for example invitations, vouchers, etc.). You can object to such contacts at any time (see at the end of this Section 4) or refuse or withdraw consent to be contacted for marketing purposes.

 

We process your data for product development, to improve our healthcare services and operations and for clinical and research development.

 

We further process your data for market research.

 

We may also process your data for security and access control purposes.

 

We process personal data to comply with laws, directives and recommendations from authorities and internal regulations Compliance»).

 

We also process data for the purposes of our risk management and as part of our corporate governance, including business organization and development.

 

We also process data for reasons of public interest in the area of public health.

 

We may process your data for further purposes, for example as part of our internal processes and administration.

5.  On what basis do we process your data?

Where we ask for your consent for certain processing activities (for example for the processing of sensitive personal data, for public use of images, for marketing mailings, for advertising management and behavior analysis on the website), we will inform you separately about the relevant processing purposes. You may withdraw your consent at any time with effect for the future by providing us written notice (by mail) or, unless otherwise noted or agreed, by sending an e-mail to us; see our contact details in Section 2. For withdrawing consent for online tracking, see Section 11. Where you have a user account, you may also withdraw consent or contact us also through the relevant website or other service, as applicable. Once we have received notification of withdrawal of consent, we will no longer process your information for the purpose(s) you consented to, unless we have another legal basis to do so. Withdrawal of consent does not, however, affect the lawfulness of the processing based on the consent prior to withdrawal.

Where we do not ask for consent for processing, the processing of your personal data relies on the requirement of the processing for initiating or performing a contract with you (or the entity you represent) or on our or a third-party legitimate interest in the particular processing, in particular in pursuing the purposes and objectives set out in Section 4 and in implementing related measures. This also includes processing your personal data to protect vital interests of data subjects, for reasons of public interest in the area of public health, or for compliance with legal regulations, where compliance is not recognized as a legal basis by applicable data protection law (for example in the case of the GDPR, the laws in the EEA and in the case of the DPA, Swiss law). This also includes the marketing of our products and services, the interest in better understanding our markets and in managing and further developing our company, including its operations, safely and efficiently.

Where we receive sensitive personal data (for example health data, biometric data for identification purposes, data about political opinions, and religious or philosophical beliefs), we may process your data on other legal basis, for example, in the event of a dispute, as required in relation to a potential litigation or for the enforcement or defense of legal claims. In some cases, other legal basis may apply, which we will communicate to you separately as necessary.

6.  With whom do we share your data?

In relation to our contracts, the website, our services and products, our legal obligations or otherwise with protecting our legitimate interests and the other purposes set out in Section 4, we may disclose your personal data to third parties, in particular to the following categories of recipients:

Group companies: A list of our group companies can be found here. These group companies may use the data according to this Privacy Notice for the same purposes as we use it (see Section 4). We may also disclose health data to our group companies.

 

Service providers: We work with service providers in Switzerland and abroad who process your data on our behalf or as joint controllers with us or who receive data about you from us as separate controllers (for example IT providers, advertising service providers, security companies, etc.). This may include health data. For the service providers used for the website, see Section 11.

 

Contractual partners including customers: This refers to customers (for example service recipients) and our other contractual partners as this data disclosure results from these contracts. If you work for one of these contractual partners, we may also disclose data about you to that partner in this This may include health data. These recipients also include contractual partners with whom we cooperate or who carry out advertising for us and to whom we may therefore disclose data about you for analysis and marketing purposes (these may again be service recipients, but also sponsors and online advertising providers). We require these partners to send you or display advertising based on your data only with your consent (for online advertising, see Section 11).

 

Authorities: We may disclose personal data to agencies, courts and other authorities in Switzerland and abroad if we are legally obliged or entitled to make such disclosures or if it appears necessary to protect our interests. This may include health data. These authorities act as separate controllers.

 

Healthcare provider and other persons: We share your information with your healthcare provider as may be necessary in connection with your Novocure therapy, as well as with third parties insofar as necessary to pursue the purposes set out in Section 4, for example service recipients, family members, research organizations, the media and associations in which we participate or if you are included in one of our publications.

 

All these categories of recipients may involve third parties, so that your data may also be disclosed to them. We can restrict the processing by certain third parties (for example IT providers), but not by others (for example authorities, banks, etc.).

In addition, we enable certain third parties to collect personal data from you on our website and at events organized by us (for example press photographers, providers of tools on our website etc.). Where we have no control over these data collections, these third parties are sole controllers. If you have concerns or wish to exercise your data protection rights, please contact these third parties directly. See Section 11 for the website.

7.  Is your personal data disclosed abroad?

As explained in section 6, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed in Switzerland, elsewhere in Europe and in the United States; in exceptional cases, in any country in the world.

We belong to Novocure Limited, a global group of affiliates with databases in different countries. Personal data we collect may be transferred, stored and otherwise processed to various destinations outside the European Economic Area (“the EEA”), including countries whose data protection provisions are not comparable to those in the EEA countries in which your personal data has been collected or provided. Novocure has an international presence and for contractual or medical purposes must also share your data with so-called third countries within the Novocure Group, in particular to Novocure Inc., which has offices in Portsmouth NH, Malvern PA, New York NY, (USA). Insofar as a recipient of your data is located in a country without adequate statutory data protection, we require the recipient to undertake additional measures to comply with data protection (for this purpose, we use the current European Commission’s standard contractual clauses, which can be accessed here, here, here and will use the revised European Commission’s standard contractual clauses, which can be accessed here, once they will enter into force), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on a derogation. A derogation may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

 

Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.

8.  How long do we process your data?

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. You will find further information on the respective storage and processing periods for the individual data categories in Section 3, and for cookies in Section 11. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.

9.  How do we protect your data?

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

10.  What are your rights?

Applicable data protection laws grant you the right to object to the processing of your data in some circumstances, in particular for direct marketing purposes, to profiling carried out for direct marketing purposes and to other legitimate interests in processing.

To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:

  • The right to request information from us as to whether and what data we process from you;
  • The right to have us correct data if it is inaccurate;
  • The right to request erasure of data;
  • The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
  • The right to withdraw consent, where our processing is based on your consent;
  • The right to receive, upon request, further information that is helpful for the exercise of these rights.

If you wish to exercise the above-mentioned rights in relation to us (or with one of our group companies), please contact us in writing, at our premises or, unless otherwise specified or agreed, by e-mail; you will find our contact details in Section 2. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).

You also have these rights in relation to other parties that cooperate with us as separate controllers – please contact them directly if you wish to exercise your rights in relation to their processing. You will find information on our key partners and service providers in Section 6 and additional information in Section 11.

Please note that conditions, exceptions or restrictions apply to these rights under applicable data protection law (for example to protect third parties or trade secrets). We will inform you accordingly where applicable.

If you do not agree with the way we handle your rights or with our data protection practices, please let us or our Data Protection Officer (Section 2) know. If you are located in the EEA, the United Kingdom or in Switzerland, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en

You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-us/. You can reach the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

11.  Do we use online tracking and online advertising techniques?

We use various techniques on our website that allow us and third parties engaged by us to recognize you during your use of our website, and possibly to track you across several visits. This Section informs you about this.

In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalization. The technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers ) that assign a specific identification number to you or your browser (so-called «cookie»). This data may also be combined with other data to be analyzed on a personally identifiable or non-identifiable basis.

 

We use these technologies on our website and may allow certain third parties to do so as well. However, depending on the purpose of these technologies, we may ask for consent before they are used. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.

We distinguish the following categories of «cookies» (including other technologies):

  • Necessary cookies: Some cookies are necessary for the functioning of the website or for certain features. For example, they ensure that you can move between pages without losing information that was entered in a form. They also ensure that you stay logged in. These cookies exist temporarily only («session cookies»). If you block them, the website may not work properly. Other cookies are necessary for the server to store options or information (which you have entered) beyond a session (i.e. a visit to the website) if you use this function (for example language settings, consents, automatic login functionality, etc.). These cookies have an expiration date of up to 24
  • Performance and Functional cookies: In order to optimize our website and related offers and to better adapt them to the needs of the users, we use cookies to record and analyze the use of our website, potentially beyond one session. We use third-party analytics services for this purpose. We have listed them below. Before we use such cookies, we ask for your consent. Performance cookies also have an expiration date of up to 24months. Details can be found on the websites of the third-party providers.
  • Targeting Cookies: We and our advertising partners have an interest in targeting advertising as precisely as possible, i.e. only showing it to those we wish to address. We have listed our advertising partners below. For this purpose, we and our advertising partners – if you consent – use cookies that can record the content that has been accessed or the contracts that have been concluded. This allows us and our advertising partners to display advertisements that we think will interest you on our website, but also on other websites that display advertisements from us or our advertising partners. These cookies have an expiration period of a few days to 12 months, depending on the circumstances. If you consent to the use of these cookies, you will be shown related advertisements. If you do not consent to them, you will not see less advertisements, but simply any other advertisement.

In addition to marketing cookies, we use other technologies to control online advertising on other websites and thereby reduce advertising wastage. You may access this website to exercise your choices about cookies and similar technologies: http://aboutads.info/choices. For example, we may transmit the e-mail addresses of our users, customers and other persons to whom we wish to display advertisements to operators of advertising platforms (for example social media). If these persons are registered with them with the same e-mail address (which the advertising platforms determine by a matching process), the providers display our advertisements specifically to these persons. The providers do not receive e-mail addresses of persons who are not already known to them. In case of known e-mail addresses, however, they learn that these persons are in contact with us and the content they have accessed.

We may also integrate additional third-party offers on our website, in particular from social media providers. These offers are deactivated by default. As soon as you activate them (for example by clicking a button), their providers can determine that you are using our website. If you have an account with the provider, it can assign this information to you and thereby track your use of online offers. The providers process this data as separate controllers.

We currently use offers from the following service providers and advertising partners (where they use data from you or cookies set on your computer for advertising purposes):

  • Google Analytics: Google LLC is the provider of the service «Google Analytics». For the purposes of the GDPR and the DPA, Google Ireland Ltd. is the controller (both «Google»). Google tracks the behavior of visitors to our website (duration, page views, geographic region of access etc.) through performance cookies (see above) and on this basis creates reports for us about the use of our website. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States and then cannot be traced back. Google provides us with reports and may therefore be considered our processor, but it also processes data for its own purposes. Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals. You should assume that this processing takes place if you consent to the use of performance cookies. Data is stored within Google Analytics for a maximum of 50 months. Information about data protection with Google Analytics can be found here and if you have a Google account, you can find more details about Google’s processing here.
  • [additional service providers, advertising partners such as Facebook if Custom Audiences is used, some of which have specific requirements on how to inform website users, etc.].

12.  What data do we process on our social network pages?

We may operate pages and other online presences («fan pages», «channels», «profiles», etc.) on social networks and other platforms operated by third parties and collect the data about you described in Section 3 and below. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.

 

We process this data for the purposes set out in Section 4, in particular for communication, for marketing purposes (including advertising on these platforms, see Section 11) and for market research. You will find information about the applicable legal basis in Section 5. We may disseminate content published by you (for example comments on an announcement), for example as part of our advertising on the platform or elsewhere. We or the operators of the platforms may also delete or restrict content from or about you in accordance with their terms of use (for example inappropriate comments).

For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects’ rights and how you can exercise them or obtain further information. We currently use the following platforms:

13.  Can we update this Privacy Notice?

This Privacy Notice is not part of a contract with you. We can change this Privacy Notice at any time. The version published on this website is the current version.