ProtaGene Group Privacy Policy

Welcome to the ProtaGene Group Privacy Policy (“Policy”).  This Policy applies to ProtaGene, GmbH, ProtaGene US, Inc., and ProtaGene CGT GmbH (collectively, “ProtaGene”, “we”, “us” or “our”) and describes our practices with respect to collecting, using, and sharing your personal data through the use of ProtaGene-operated websites (“Site” or “Sites”), including and any other ProtaGene product or service that links to this Policy. We take your privacy and the protection of your information seriously.

This Policy does not cover other ProtaGene services that do not link to this Policy.

This Policy is incorporated into, and is part of, our Terms of Use available at which govern your access to the Site and your use of the Site, unless you have entered into a separate written agreement with ProtaGene. If you have entered into a separate written agreement with ProtaGene, that separate written agreement shall control, and only those terms within this Policy that do not conflict with said separate written agreement shall apply. Unless otherwise defined herein, capitalized terms shall have the meaning assigned to such terms in the Terms of Use.

If you have any questions regarding this Policy please contact us at

This Policy describes the types of information we gather from people visiting our Site and from individual users (“you” or “users”) interacting with our Site, as well as how we use, transfer, and secure such information. By accessing any Site, you agree to be bound by this Policy. This Policy does not govern information we receive from third parties. If you do not agree to the terms of this Policy, please do not use the Site. Each time you use any Site, the current version of this Policy will apply. Accordingly, when you use any Site, you should check the date of this Policy (which appears at the top) and review any changes since you last reviewed the Policy.

1. Types of Information We Collect

We collect two types of information from users of our Sites: “Personal Information,” which is information that you provide that can be used to identify you (such as name, email address, etc.), and “Aggregate Information,” which is information that cannot be used to identify you (such as frequency of visits to the Site, browser type, etc.)

1.1   Personal Information Collected

1.1.1   We collect Personal Information that you voluntarily provide to us when you use our Site. For example, you may provide us with your email address, first name and last name, phone number, company, job title, area of interest, company phase of development, or other Personal Information, such as when you sign up for our newsletter.  We also collect personal information in person at trade shows and similar events that we attend.

1.1.2  Careers.  If you apply for a position through our Sites, via email, or through our social media accounts (e.g. LinkedIn), we collect your name, email address, cover letter, and any other information that you decide to provide us.  We use your information to evaluate your candidacy for the position you applied for as well as other positions at ProtaGene Group.

1.1.3  Online Chat.  If you communicate with us through the online chat function on our Site, we collect any information that you share with us through the chat.  We use a third party, Drift, to provide such services.

1.1.4  Social Media.  We may collect your profile information and any information that you provide to us when you interact with us through our social media accounts.

1.1.5   If you choose to share information publicly through our Site please understand that we cannot control the actions of third parties who could collect this information.

1.2   Collection of Personal Information by Third Parties

1.2.1   Some links on our Site may redirect you to third party websites that we do not operate. The privacy practices of those websites will be governed by their own policies. We make no representation or warranty as to the privacy policies of any third parties, including the providers of third party applications. If you are submitting information to any such third party through our Site, you should review and understand that party’s applicable policies, including their privacy policy, before providing your information to the third party. Also note that a third-party services linked to our Site may install cookies on your device, which we have no control over. If necessary, please contact such third parties directly for more information.

1.3   Aggregate Information Collected

1.3.1   Aggregate Information is information that does not identify you. Aggregate Information may be collected when you visit our Site, independent of any information you voluntarily enter. Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains. We may collect, use, store, and transfer Aggregate Information without restriction.

1.3.2   For example, when you visit our Site, some information is automatically collected. Such information could include your operating system, the site from which you linked to us (“referring page”), the name of the website you choose to visit immediately after ours (called the “exit page”), information about other websites you have recently visited, browser (software used to browse the internet) type and language, device identifier numbers, your site activity and functions used, IP address, and the time,date, and duration of your visit. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.

1.4   Use of “Cookies”

1.4.1.  Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to help us identify you when you come to our Site. You have choices with respect to cookies.

By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you may be unable to use those aspects of our Sites that require registration in order to participate. You can learn more about cookies and how they work at You can always disable cookies through your browser settings. Doing so, however, may disable certain features on our Sites. You can opt-out from third party cookies that are used for advertising purposes on the NAI website at

1.5   Analytics

1.5.1   We may use third parties, such as Google Analytics or other analytics providers described in detail below, to analyze traffic to our Site. It may also be possible to determine whether a user profile was created as a result of an advertising measure. We also use these tools to prevent and combat fake profiles, illegal activities and spam, and to increase the security of the Site. To perform the analysis, user data is transmitted to various third-party providers as described in this Policy.

1.5.2  We may also use cookies, pixels, beacons, or other web tracking technologies to track the amount of time spent on our Sites or social media and whether or not certain content, such as a video was viewed. We may work with a third party to collect and process this information for us, based on our instructions and in compliance with this Policy.

1.5.3  Google Analytics – We use Google Analytics, a web analytics service provided by Googleon the Site. Google uses cookies, and the information generated by the cookie about the use of the Site by users is typically transmitted to a Google server in the U.S. and stored there. Google uses this information on our behalf to evaluate the use of our Site, to compile reports on the activities on our Site and to provide us with other services related to the use of our Site. In doing so, pseudonymous usage profiles can be created from the processed data.

If you do not want cookies to be stored by Google Analytics on your device, you can deactivate the corresponding option in the system settings of your browser. You can delete stored cookies in the system settings of your browser at any time. In addition, you can disable the use of Google Analytics cookies by means of a browser add-on. You can download this add-on here:

1.5.4  SalesViewer – Our Site uses SalesViewer® GmbH, Huestraße 30, 44787 Bochum, Germany, to collect and store data for market research and optimization purposes using the SalesViewer® technology.  A javascript-based code is used to collect company-related data and the corresponding usage. The data collected using this technology is encrypted using a non-reversible one-way function (known as hashing). The data is immediately pseudonymized and not used to personally identify the visitor to our Site.  You can object to the collection and storage of data at any time with effect for the future by clicking on this link to prevent the collection of data by SalesViewer® within this website in the future. This will place an opt-out cookie for this Site on your device. If you delete your cookies in this browser, you must click this link again.  You can find more information about data protection with this provider at

1.5.5  ClickDimensions – We use the Click-Dimensions analysis and service tool on our Site provided by ClickDimensions LLC, 5901 Peachtree Dunwoody Road, NE Suite B500, Atlanta, GA 30328, USA. ClickDimensions collects and analyzes data about the behavior of users of a website. This data includes, among other things, access to websites and the length of time spent on them.  ClickDimensions is an analysis tool to provide users with information relevant to their interests based on their behavior on the Site and to optimize marketing activities. ClickDimensions uses cookies, which are stored in the user’s browser and enable an analysis of the user’s use of the Site.

If you do not want Click-Dimensions to store cookies on your end device, you can deactivate the corresponding option in the system settings of your browser. You can delete stored cookies in the system settings of your browser at any time. For further information on the use of data by ClickDimensions, please refer to the ClickDimensions data protection declaration at:

1.6   Interest-Based Advertising

1.6.1   We may also participate in interest-based advertising using similar technology. This means that you may see advertising on our Sites tailored to your interests, or you may see advertising for ProtaGene and its products or services on other websites based on your browsing behavior across websites. Some websites where we may advertise belong to ad networks that use your web browsing history to choose which ads to display on their network websites; these ads include advertising for ProtaGene and its Sites. Other websites where you see our ads, such as Google Re-Targeting, may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you. Some internet browsers, websites such as Facebook and mobile devices offer opt-outs for interest-based advertising. Please refer to the website that you are visiting, your browser and/or your device settings for additional information.

1.6.2   You can opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website ( and DAA website (

2. Sharing of Personal Information with Third Parties

2.1   We may transfer or disclose Personal Information to our affiliate and subsidiary entities in the ProtaGene Group, as well as with third parties for the purpose of providing the Site and operating our business. For example, we may transfer your Personal Information to third party service providers to (i) assist with providing the Site; (ii) communicate with you about current or future offerings. Our third party service providers are not authorized to retain, share, store or use the Personal Information for any purposes other than to provide the services they have been hired to provide, and in accordance with our instructions.

2.2  Promotions and Contests.  We may disclose your Personal Information to third parties if we offer promotions, competitions, contracts, or similar services together with partners or service providers (e.g., transport service providers).

2.3   We may also elect to transfer your Personal Information to third parties under special circumstances to: (i) to comply with a legal requirement, judicial proceeding, court order, or legal process served on Us; (ii) to investigate a possible crime, such as fraud or identity theft; (iii) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of a ProtaGene entity, or steps taken in anticipation of such events (e.g., due diligence in a transaction); (iv) when we believe it is necessary to protect the rights, property, or safety of ProtaGene or other persons, or (v) as otherwise required or permitted by law, including any contractual obligations of ProtaGene.

3. Your Choices

3.1   You have the right to make requests regarding your Personal Information. You can:

  • Right to information: you have the right to obtain information on your personal data that we store.
  • Right to correction and erasure: you may obtain from us that we correct inaccurate data and erase your data.
  • Restriction of processing: you may obtain from us that we restrict the processing of your data.
  • Data portability: if you provided your data to us based on a contract or consent, we may request from us to receive the personal data which concerns you in a structured, commonly used, and machine-readable format and that we transmit those data to another controller.
  • Object to data processing with respect to the legal grounds “legitimate interest”: where required by applicable law, you have the right to object, on grounds relating to your situation, at any time to processing of your Personal Information provided it is based on the legal grounds “legitimate interest”. Should you make use of your right to object, we will discontinue processing your Personal Information, unless we can demonstrate compelling legitimate grounds for further processing that outweigh your rights.
  • Object to cookies: you may also object to the use of cookies at any time.
  • Withdrawal of consent: if you have given your consent to processing your Personal information, you may withdraw your consent with immediate effect at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
  • Right to appeal with the supervisory authority: where required by applicable law, you may also submit an appeal with the responsible supervisory authority if you feel that the processing of your Personal Information violates applicable law. To do so, you may address the data protection authority that is responsible for your place of residence or your country or to the data protection authority that is responsible for us.

These rights vary depending on where you reside. However, although we cannot guarantee to do so in all cases, we generally will make reasonable efforts to fulfill your request, even if your country or state does not require us to do so.  If you ask us to delete or stop using your personal data, we may not be able to fulfill that request if the personal data is required to fulfill our obligations to you, or comply with tax, audit or regulatory requirements.

If you have any questions regarding the processing of your personal data, your data subject rights and any consent you may have given, you can contact us free of charge. To exercise all your rights, please contact us (for contact details, please refer to section 1 above). Please ensure that we are able to clearly identify you.

Residents of California have additional rights.  Please see our California Consumer Privacy Act Notice for details.

3.2   If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each communication.

4. Children and Privacy

4.1   We do not knowingly collect Personal Information from children in connection with the features of our Sites. If we become aware that an individual under the age of 13 has provided personally identifiable information through our Sites, we will immediately remove the individual’s personally identifiable information from our files.

5. EEA Residents

Your personal data will be processed in compliance with the legal provisions of the data protection laws of the European Union, in particular the General Data Protection Regulation (hereinafter referred to as “GDPR”) and, in addition, the German Federal Data Protection Act (“Bundesdatenschutzgesetz”). The terms used in this Section such as “personal data” or their “processing,” correspond to the definitions in Art. 4 GDPR.


5.1. Controller and Data Protection Officer

Responsibility for data processing as defined in European data protection laws is:

ProtaGene GmbH
Inselwiesenstraße 10
74076 Heilbronn
Phone: +49 7131 74 50 40

You can see our imprint here at:

If you have any questions or suggestions regarding data protection, please feel free to contact us.

You can reach our Data Protection Officer as follows:

DataCo GmbH
Dachauer Str. 65
80335 Munich 

 5.2. Subject matter and principles of data protection

 Personal data is the subject matter of the data protection This is all information that relates to an identified or identifiable natural person (so-called data subject). This includes, for example, information such as name, postal address, e-mail address or telephone number, but also information that necessarily arises during the use of our Site, such as information about the beginning, end and extent of use and the transmission of your IP address.

We process personal data in compliance with the relevant data protection regulations. This means that your data will only be processed by us if you have given your consent or if we are legally permitted to do so, e.g. if the data processing is necessary for the provision of our contractual services (e.g. processing of orders) or is required by law, or on the basis of our legitimate interests as defined in Art. 6 (1) (f) GDPR (e.g. our interest in the analysis, optimization and secure operation of our Site).

We take organizational, contractual and technical security measures in accordance with the state of the art to ensure compliance with data protection regulations and to protect the data we process against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

5.3 Cookies:

Where required, we have implemented the WordPress content management system to enable you to make certain cookie choices. The cookies necessary for the functions of the Site and the services offered are pre-set. The data processing is therefore carried out in this respect to protect our legitimate interests based on Art. 6 (1) (f) GDPR. Our legitimate interest is the provision and maintenance of our Site.

By unchecking the box, you can prevent the setting of cookies in the appropriate category. WordPress is used to provide you with a quick overview of the cookies used on the Site and to give you the opportunity to make individual settings regarding the setting and use of cookies. For more information on the categories and the settings to be made in this regard, please refer to the cookie banner on our Site.

5.4 Analytics:

We only use Google Analytics with IP anonymization activated. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by your browser will not be merged with other Google data.

If you do not want cookies to be stored by Google Analytics or any other analytics tool on your device, you can refuse or withdraw your consent in our cookie banner to this extent.

The data processing associated with Google Analytics is carried out based on your consent in accordance with Art. 6 (1) (a) GDPR. Insofar as data is transferred to the USA, so-called standard contractual clauses in accordance with Art. 46 GDPR for advertising services of Google have been concluded with Google as appropriate guarantees ( Besides that, Google is certified under the Privacy Shield agreement. Further information on data use by Google, setting and withdrawal options, as well as options to object, can be found in Google’s privacy policy at:

Our processing of personal data through our use of SalesViewer, as described above, is based on the legitimate interests of the website operator (Art. 6 (1) (f) GDPR).

Our processing of personal data through our use of ClickDimensions is based on your consent in accordance with Art. 6 (1) (a) GDPR. The recipient of the data is ClickDimensions as a processor. For this purpose, we have concluded the corresponding data processing agreement with ClickDimensions. The data will be deleted as soon as it is no longer required for our recording purposes. The data stored in the cookie is transferred to a server of a Microsoft Azure Data Center and stored there; it cannot be ruled out that data is transferred to the USA. Insofar as data is transferred to the USA, so-called standard contractual clauses pursuant to Art. 46 GDPR have been concluded with ClickDimensions as suitable guarantees.

5.5 Newsletter:

We only send newsletters after corresponding registration, i.e., with your consent based on Art. 6 (1) (a) GDPR. If the contents of the newsletter (i.e., the advertised goods and services) are specifically described in the registration, they are decisive for the scope of the consent. In addition, our newsletters contain information about our products, offers, promotions and / or our company.

The registration takes place by means of the so-called double-opt-in procedure, i.e., after your registration you will receive an e-mail in which you are asked to confirm your registration to prevent the misuse of your e-mail address. We log the registration for the newsletter in order to prove the registration process in accordance with legal requirements and, if necessary, to prevent or clarify any misuse of your personal data. The logging of the registration process is based on our legitimate interests in accordance with Art. 6 (1) (f) GDPR in the operation of a user-friendly and secure newsletter system and to be able to prove the registration process and the consent given at a later date.

You can withdraw your consent to receive our newsletter at any time, by unsubscribing from the newsletter. You will find an unsubscribe link to exercise this right at the end of each newsletter. If you have only subscribed to our newsletter, your personal data will be deleted by us in the event of unsubscription.

Our newsletters contain so-called tracking pixels (web bugs), which enable us to recognize whether and when an e-mail was opened and which links in the e-mail were followed by the personalized recipient. We save this data so that we can tailor our newsletters to the wishes and interests of our subscribers. Accordingly, the data thus collected is used to send personalized newsletters to the respective recipient.

The evaluation and performance measurement of the newsletters are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter dispatch, which serves both our business interests in direct marketing and in the development and maintenance of our customer relationship, as well as the expectations of the users.

We use the service of ClickDimensions to send our newsletter. ClickDimensions acts as our processor and processes the data exclusively according to our instructions. The provider is ClickDimensions LLC, 5901 Peachtree Dunwoody Road, NE Suite B500, Atlanta, GA 30328, USA. You can find more information about data protection with this provider here:

5.6 Online Chat:

We use the chat function of Drift (, Inc. 222 Berkeley Street, Suite 600 Boston, MA 02116, USA) on some pages of our Site. The chat and the associated data processing will only be started if you have previously agreed to this in the cookie banner. By default, the chat is not loaded and therefore no personal data is collected from you. Your IP address collected during chat use is stored in anonymized form in the Cookies and is not used to identify you personally.

You can decide what personal data you disclose about yourself in the chat. In particular, you do not have to give your real name, but can also use the chat anonymously by giving a pseudonym. The data you provide will be processed exclusively for the purpose of conducting the consultation and ensuring its quality. For the execution of the chat, only data that is necessary for the consulting service or for the completion of your request will be used. This data is processed exclusively by us and our service providers. The data is usually transferred to a Drift server in the USA and stored there. The full IP address is only transferred to a Drift server in the USA after a call has been actively initiated, and only for the duration of this call. In addition, if specified, your email address and your conversation with us will be stored for the duration of the conversation.  The legal basis for the processing of the automatically collected metadata as well as the data freely provided by you in the chat history is your consent pursuant to Art. 6 (1) (a) GDPR. You give us this consent by accepting the cookies and voluntarily providing personal data in the chat. Insofar as the chat is in connection with a potential job application with us, the legal basis for the processing is Art. 6 (1) (b) GDPR or § 26 (1) BDSG. Here, we only use your personal data to answer your questions. The chat history is not linked to a specific application. In addition, we use the input to improve our consulting services and for quality assurance. In this respect, we process your personal data based on Art. 6 (f) GDPR. Our legitimate interest in processing the collected data also lies in the continuous improvement of our consulting services within the framework of the chat.

The data collected in connection with the chat will be deleted or blocked by us as soon as the purpose of the storage no longer applies. A storage can take place beyond that, if this is prescribed by the European or national legislator. Data will also be deleted or blocked if a legally prescribed storage period expires unless there is a need for further storage of the data for the conclusion or fulfilment of a contract. In the case of consent, you have the right to withdraw it at any time without affecting the lawfulness of the processing carried out on the basis of the consent until revocation.


5.7 Our Legal Bases For Processing:

  • Web browsing data: We process this data on the basis of our legitimate interests within the meaning of Art. 6 (1) (f) GDPR, namely for the provision and display of the Site, to ensure and maintain technical operation, for the purpose of identifying and eliminating faults and for security reasons (e.g., to clarify cases of abuse or fraud). When you access our Site, this data is automatically processed. Without this provision, you cannot use our Site. We do not use this data for the purpose of drawing conclusions about your identity. The collected data is deleted when we no longer need it to fulfil the above-mentioned purposes.
  • Contact-Us data: If you provide us with personal data by e-mail or via a contact or other online form, this is always done on a voluntary basis. Your personal data will be processed by us for the purpose of handling your contact request and its processing in accordance with Art. 6 (1) (b) GDPR and may also be passed on to affiliated companies or third parties in this context. In this respect, the information may also be stored by us in our customer relationship management (CRM) system. We delete the data provided by you as soon as the purpose of the collection is no longer applicable and no further legal basis intervenes (e.g., the further processing of the data is or becomes necessary for the fulfilment of a concluded contract). If and as long as there are legal obligations to retain data, we will delete the data only after the expiry of the corresponding periods.
  • Careers data: The legal basis for processing your personal data in an application process is in particular Section 26 (1) of the German Federal Data Protection Act (BDSG). Accordingly, the processing of data is permissible insofar as it is necessary in connection with the decision on the establishment of an employment relationship. Any additional information voluntarily provided by you is stored based on Art. 6 (1) (f) GDPR, as we have a legitimate interest in also processing the additional information voluntarily provided by you for the purposes of carrying out the application process. If you agree to the further storage of your personal data in our applicant pool after the unsuccessful completion of the application process, the legal basis for the associated further processing is your consent pursuant to Art. 6 (1) (a) GDPR. You can withdraw your consent at any time with effect for the future without giving reasons.  Personal data of applicants will be deleted by us after six months at the latest in the event of rejection. In the event that you have consented to further processing of your personal data in our applicant pool, the data will be deleted when it is no longer necessary for the purposes for which it was collected and processed, usually after a period of 2 years after inclusion in the applicant pool. If you are selected for a position as part of the application process, your data will be transferred to our personnel administration system and processed there insofar as it is required for the establishment and implementation of the employment relationship.
  • Governmental Authorities: If we are legally-compelled to disclose your personal data to governmental authorities, the transmission takes place based on Art. 6 (1) (c) GDPR.
  • Promotions and Contests: when we disclose your personal data to third parties for promotions, competitions, contracts, or similar services together with partners or service providers (e.g., transport service providers), the transfer of data takes place based on consent, for the performance of a contract with you or for the protection of our legitimate interests pursuant to Art. 6 (1) (a), (b) and/or (f) GDPR. You will receive more detailed information in this respect when providing your personal data in connection with the specific processing operation.
  • Third-party services and content: We use content or service offers of third-party providers based on our legitimate interests within the meaning of Art. 6 (1) (f) GDPR, namely our interest in the analysis, optimization, and economic operation of our Site, in order to integrate their content and services, such as videos (hereinafter uniformly referred to as “content”). This always requires that the third-party providers of this content are aware of the IP address of the user, since without the IP address they could not send the content to their browsers. The IP address is thus necessary for the display of this content. We strive to use only such content whose respective providers use the IP address only for the delivery of the content.

5.8 Data processing in third countries

If data is transferred to bodies whose registered office or place of data processing is not located in a member state of the European Union or in another state party to the Agreement on the European Economic Area, we will ensure prior to the transfer that, outside of exceptional cases permitted by law, either an adequate level of data protection exists at the recipient’s site (e.g. by means of an adequacy decision or through suitable guarantees such as the agreement of so-called EU standard contractual clauses of the European Union with the recipient) or your consent to the data transfer exists.

5.9 Storage Duration

For information on the storage duration of personal data, please review the corresponding description of relevant product or service. In addition, or unless defined otherwise in the relevant description of the product or service, the following applies generally: we store your personal data only for as long as required to meet the processing purposes or, if consent is given, if you have not withdrawn your consent. If you object, we will erase your personal data, unless further processing thereof is permitted in accordance with relevant legal provisions. We will also erase your personal data if we are required to do so for legal reasons. Insofar as legal storage obligations exist, we will not erase the data until the relevant deadlines have expired.

6. California Residents

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, visit the Privacy Notice for California Residents.

7. How Do We Protect Your Information

6.1   We take the security of your Personal Information very seriously. We use reasonable administrative, physical, and technical safeguards to secure the Personal Information you share with us. Despite these safeguards and our additional efforts to secure your information, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third-parties will not be able to defeat our security and improperly collect, access, steal, or modify your Personal Information.

8. Will We Change This Privacy Policy?

7.1   Each time you use our Site the current version of the Policy will apply. When you use our Site, you should check the date of this Policy (which appears at the top of the Policy) and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. Unless stated otherwise, our current Policy applies to all information that we have about you. We will not materially change our policies and practices to make them less protective of your privacy without the consent of affected customers.

9. How Do You Contact Us?

8.1   To contact us with your questions or comments regarding this Policy or the information collection and dissemination practices of this website, please email us at

10. Governing Law

9.1   This Policy is governed by the laws of the Commonwealth of Massachusetts, U.S.A. without giving effect to any principles of conflict of law.