Hatsy (Pty) Ltd t/a Topbet Online
(hereinafter referred to as “Hatsy”)
Affiliate Program Contract
The Affiliate’s participation in the affiliate program is subject to Hatsy’s terms and conditions set our herein below, and the Affiliate’s completion of an application form. In the event that the Affiliate does not wish to accept the terms and conditions set out hereinbelow, the Affiliate ought not submit an application to participate in such program.
In the event that the Affiliate has any questions regarding Hatsy’s affiliate program, the Affiliate is urged to contact Hatsy, utilising the email address affiliates@topbet.co.za, for further information.
TERMS AND CONDITIONS OF AFFILIATE PROGRAM
1. Definitions In this Agreement, unless the context otherwise requires: 1.1. "Act" means the National Gambling Act No. 7 of 2004; 1.2. Advertising Regulatory Board" means a Board that administers the Code of Advertising Practice in South Africa; 1.3. "Affiliate" means the person entering into this Agreement with Hatsy, being either an individual person or an entity, who wishes to participate in Hatsy’s Affiliate Program, subject to the terms and conditions set out herein; 1.4. "Affiliate Program" means the collaboration between the Affiliate and Hatsy, in terms of which the Affiliate will promote Hatsy, the Website and the Topbet brand, and the Affiliate will utilise the Link provided to him/her/it, in order to do so on the Affiliate Website and/or any approved social media, and in respect of which services the Affiliate will be paid a commission on the terms and conditions set out herein; 1.5. "Affiliate Website(s)" means one or more websites on the internet which are operated and maintained by the Affiliate; 1.6. "Confidential Information" means all information, in whatever medium, relating to the trade secrets, operations, processes, plans, intentions, product information, know-how, design, market opportunities, transactions, affairs or business of a party to this Agreement or its customers, suppliers, holding companies or subsidiaries, the terms or subject matter of this Agreement, and the negotiations relating to this Agreement; 1.7. "Gross Referral Revenue (GRR)" means the sum of Hatsy’s gross revenue generated in respect of the Affiliate’s referrals in the period of one calendar month; 1.8. “Hatsy” means Hatsy (Pty) Ltd t/a Topbet, a company with limited liability, duly incorporated in terms of the laws of the Republic of south Africa, with registration number 2021/566466/07, and having its principal place of business at 47 Thembi Place, 15 Calderwood Road, Lonehill, Gauteng; 1.9. “Net Revenue” means the Gross Referral Revenue received by Hatsy on a monthly basis, less:- 1.9.1. any sums paid to the Referred Customer as winnings; 1.9.2. any sums paid in respect of tax to either the Gambling Board and/or SARS; 1.9.3. any sums not yet settled by the Referred Customer; 1.9.4. any losses suffered as a result of fraud by the Referred Customer; 1.9.5. any returned stakes; 1.9.6. transactions which are reversed by instruction from the cardholder’s bank (commonly known as charge-backs); 1.9.7. any void bets; 1.9.8. any bet/deposit bonuses or any bonuses of any kind; 1.9.9. any amounts given to the Referred Customer as a result of a promotion; 1.9.10. a 33% administration fee in respect of deposits administration costs, licence fees and operational costs; 1.9.11. any commission/fees payable by Hatsy for providing contingencies; 1.9.12. any financial transaction fees. 1.10. "Intellectual Property” means any creation of the mind that is recognised and/or capable of being protected by law from use by any other person, whether in terms of South African law or foreign intellectual property law, including but not limited to source code, algorithms, hardware, circuits, computer languages, computer programs, applications, databases, user interfaces, application programming interfaces, encoding techniques, methodologies, specifications and formulae, procedures, processes, plans, data, diagrams, photographs, know-how, marketing and production techniques, models, systems, reports, statements, templates, utilities, memoranda, reports, drawings, prototypes and computer modelling, trade secrets, inventions, trademarks, designs, works eligible for copyright, whether registrable, registered or the subject matter of an application for registration or not, and all statutory intellectual property, including all patents, design and trade mark registrations and copyrighted works; 1.11.“Link” means the link to be provided to the Affiliate which will be utilised to link any Referred Customers to the Affiliate, for the purposes of paying the Affiliate any commission due to the Affiliate in terms hereof; 1.12."POPI ACT" means the Protection of Personal Information Act No. 4 of 2013; 1.13."Referred Customers" means customers who do not have an account with Hatsy, and who have signed up for an account with Hatsy, utilising the Link, and which customers comply with any and all of Hatsy’s requirements in order to establish a business relationship, including but not limited to the submission of any FICA documents; 1.14.“Website” means www.topbet.co.za, or any other website as designated by Hatsy from time to time. 2. Agreement 2.1. This annexure (the "Agreement") outlines the terms and conditions applicable to the relationship between Hatsy and the Affiliate, in respect of the relationship between Hatsy and the Affiliate. 2.2. The Affiliate’s role, as part of Hatsy’s affiliate program, will be to promote the Website, and further to promote Hatsy’s brand and services, and to encourage individuals to transact with Hatsy. 2.3. Hatsy reserves the right to update or modify the terms of this Agreement, and in which event the Affiliate will be given notice of the amendments by way of e-mail 5 (five) days prior to the changes being implemented. In the event that the Affiliate is not in agreement with the proposed changes to the terms and conditions of this Agreement, then the Affiliate is required to notify Hatsy within such 5 day period, and whereupon this Agreement between Hatsy and the Affiliate will terminate with immediate effect. If the Affiliate does not communicate his/her/its dissatisfaction with the changes and the Affiliate continues to participate in Hatsy’s affiliate program after the changes have been implemented, Hatsy deems that the Affiliate has accepted the changes to the terms and conditions. All changes will also be published on the Website. 2.4. The Affiliate’s application to participate in Hatsy’s affiliate program is subject to Hatsy’s consent. Upon completion and submission of the application form, Hatsy will review the application and communicate its approval of such application. Hatsy’s decision is final and binding. Hatsy’s decision will be communicated to the Affiliate by way of e-mail, and in the event that the Affiliate’s application is approved, these terms and conditions will immediately be applicable and binding between the parties. 3. Link and QR Code 3.1. Hatsy shall provide the Affiliate with the Link, and may also provide a QR Code, which must be displayed by the Affiliate on the Affiliate Website, and used by the Affiliate in the manner agreed to between Hatsy and the Affiliate in terms hereof. 3.2. The Affiliate shall not be permitted to change the form, location or operation of the Link without Hatsy’s prior written consent. 3.3. The Affiliate shall ensure that he/she/it does not place the Link on pages of the Affiliate Website aimed at persons under the age of 18 years. Furthermore, the Affiliate must display any and all taglines and/or advertising and/or marketing material related to responsible gambling, and also a prominent sign that gambling is not permitted by persons younger than 18 years of age. 3.4 In the event that the Affiliate wishes to advertise the Link on a website other than the Affiliate Website, the Affiliate is required to obtain Hatsy's prior written consent. 3.5 In the event that Hatsy ascertains that the Affiliate has utilised the Link in a manner which is not compliant with the terms of this Agreement, then Hatsy shall be entitled to disable the Link and to terminate the Agreement in writing, without any notice to the Affiliate. 4. Commission
4.1. In respect of the Affiliate’s referral of the Referred Customers, the Affiliate shall be entitled to commission, calculated in accordance with the following structure which is based on the number of Referred Customers: -
New Referred Customers
Commission
1-25
15%
26-100
20%
101-399
30%
400 or more
35%
4.2. The commission structure set out in 4.1 above shall apply to all contingencies made available by Hatsy for Referred Customers to bet in respect of.
4.3. No VAT shall be payable in respect of the commission payable to the Affiliate, unless the Affiliate is a registered VAT vendor.
4.4. As set out in clause 2.3, Hatsy reserves the right to amend these terms and conditions, and in terms thereof, further reserves the right to amend the commission payable to the Affiliate, and the minimum and maximum Net Revenue set out hereinabove.
5. Minimum Requirements
5.1. The Affiliate is required to refer a minimum of 1 (one) new customer per month, who must sign up for an account with Hatsy to qualify for commissions.
5.2. In the event that the Affiliate does not refer the aforesaid minimum of 1 (one) new customer per month, for a period of 3 (three) consecutive months, then Hatsy reserves the right to:-
5.2.1. reduce the commission rate to a rate of 5% (five percent) upon written notice to the Affiliate; alternatively
5.2.2. terminate this Agreement with immediate effect.
6. Forbidden Practices
6.1. The Affiliate is not permitted to offer added rewards of any kind to Referred Customers without Hatsy’s prior written consent. In the event that the Affiliate does so, Hatsy reserves the right to terminate the Agreement, and to cease any further payments to the Affiliate.
6.2. The Affiliate is not permitted to attempt to or to artificially increase monies payable to the Affiliate by Hatsy.
7. Compliance with Laws
7.1. The Affiliate undertakes to comply with any and all applicable legislation, including but not limited to the Act, the applicable gambling laws in each province, POPIA, and any regulations issued pursuant thereto.
7.2. More particularly, the Affiliate undertakes:-
7.2.1. not to in any way advertise to customers who did not expressly and clearly consent to receive marketing communications, or which consent the Affiliate has not stored and is not able to prove, or to customers which data have been processed in breach of POPIA;
7.2.2. that every email transmitted by the Affiliate will clearly set out that it is transmitted by the Affiliate and not by Hatsy;
7.2.3. that any marketing e-mails transmitted will contain a clear link to an unsubscribe option from further marketing emails.
7.3. The Affiliate is specifically required to abide by the provisions of the Act, together with any provincial legislation in respect of advertising, together with any other legislation which may be applicable to advertising, including but not limited to the Code of Advertising Practicein South Africa, as determined by the Advertising Regulatory Board.
7.4. The Affiliate is required to ensure that marketing communications do not amount to or involve misleading statements or misleading omissions. Any marketing communications must include relevant terms and conditions, together with a statement that under 18’s are not permitted to gamble, and the tagline for responsible gambling. Where an advert is limited by space, significant conditions must be displayed no further than one click away from the advert itself.
7.5. The above requirements are applicable to all forms of marketing communication, including social media and other forms of advertising such as newspapers. Hatsy reserves the right to terminate the Agreement immediately if, in Hatsy’s reasonable opinion, the Affiliate has breached any applicable legislation, rules and/or regulations in respect of advertising.
8. Marketing and/or Advertising
Any marketing material and/or advertising to be published by or on behalf of the Affiliate must be transmitted to Hatsy, for its prior written approval, prior to being publicised.
9. Hatsy's Obligations
9.1. Hatsy shall supply the Affiliate with the Link for inclusion on the Affiliate Website and may update such Link from time to time.
9.2. Hatsy shall use its best endeavours to ensure that when a Referred Customer signs up with Hatsy through the Link, the customer is identified as originating from the Affiliate Website. However, Hatsy shall not be liable in any way if Hatsy is unable to identify a customer as originating from the Affiliate Website.
10. Payment Terms and Payment
10.1.Payment of any sum due, owing and payable to the Affiliate in terms hereof shall be made on the 15th of every calendar month to the Affiliate, directly into the Affiliate’s bank account indicated on the first page hereof.
10.2.The minimum sum in order to effect payment to the Affiliate shall be R500.00 (five hundred Rand). If the sum to which the Affiliate is entitled to does not exceed R500.00 (five hundred Rand), then Hatsy shall be entitled to withhold and carry forward such sum until the end of the next calendar month in which the sum to which the Affiliate is entitled exceeds R500.00 five hundred Rand), at which time payment shall be made.
10.3.Hatsy shall provide the Affiliate with statements in respect of the sums due, owing and payable to the Affiliate through the personal affiliate page, which may be found www.affiliates.topbet.co.za.
10.4.The Affiliate hereby acknowledges that he/she/it is responsible for any payments due to SARS in respect of amounts paid to the Affiliate by Hatsy, and specifically indemnifies Hatsy in respect of any and all sums payable to SARS by virtue of the fact that Hatsy makes payments to the Affiliate.
11. Intellectual Property
11.1.Hatsy hereby grants the Affiliate a non-exclusive and worldwide licence to display the intellectual property belonging to Hatsy during the term of this Agreement, solely for the purposes of the display of the Link by the Affiliate on the Affiliate Website, and the promotion thereof.
11.2.Hatsy is at all times entitled to review the display of its Intellectual Property on the Affiliate Website, and to require that the Affiliate make amendments thereto, by which directive the Affiliate is bound to comply.
11.3.The Affiliate agrees that the Affiliate Website shall not resemble in any way the look and/or feel of the Website, nor will the Affiliate create the impression that the Affiliate Website is the Website (or any part thereof).
12. Role and Capacity of the Affiliate
It is understood and agreed by the parties hereto that this Agreement does not create a fiduciary relationship between them, and that the Affiliate shall be an independent contractor, and its employees shall not be employees of Hatsy, and that nothing in this Agreement is intended to make either party a general or special agent, joint venturer, partner or employee for the other, for any purpose.
13. Confidentiality
13.1.Each party shall, for the duration of this Agreement and thereafter:-
13.1.1. keep all Confidential Information disclosed to it by the other party strictly confidential;
13.1.2. not disclose any such disclosed Confidential Information to a third party, other than such of its employees, officers or professional advisors on a “need to know” basis, and only provided that the relevant party shall ensure that such employee, officer or advisor shall keep such Confidential Information confidential, and shall not use any of it for any purpose or disclose it to any person, firm or company, other than those for which or to whom the party may lawfully use or disclose it under this Agreement;
13.1.3. use Confidential Information only in connection with proper performance in terms of this Agreement.
13.2.Without limiting the above provisions, save as required by applicable law or any competent authority, existing contractual obligations or any applicable regulatory authority or government body to which a party is subject (wherever situated), no party shall make any public announcement, issue any press release or make any form of statement to the public about this Agreement or any ancillary matter without the prior written consent of the other party, which shall not be unreasonably withheld or delayed.
13.3.This clause shall not apply to any Confidential Information, to the extent that it:-
13.3.1. comes within the public domain, other than through a breach of this clause;
13.3.2. is required or requested to be disclosed by any competent authority to which a party is subject, wherever situated. The parties agree that in the event that either party is requested or required to disclose such information, they shall provide the other party with prompt notice of such demand or request, and shall consult and cooperate with the other party in connection with such disclosure;
13.3.3. it is known to the receiving party before the disclosure to it by a party to this Agreement or on its behalf, as proven by written records; or
13.3.4. is disclosed with the other party’s prior written approval to the disclosure.
13.4.This clause shall continue in force after and despite the termination of this Agreement, for whatsoever reason.
14. No Solicitation
For the duration of this Agreement and for the period of 1 (one) year thereafter, either party to this Agreement shall not, directly or indirectly, hire or solicit any employee of the other party or anyone who was an employee, consultant or independent contractor of the other party at any time within a 6 (six) month period immediately prior thereto, or encourage any employee, consultant, independent contractor or agent of the other party to terminate such employment, or its agency or other relationship with the party.
15. Warranties
15.1.Each party to this Agreement represents and warrants to the other that it has, and will retain throughout the term all right, title and authority to enter into this Agreement, to grant to the other party the rights and licenses granted in this Agreement and to perform all of its obligations under this Agreement.
15.2.The Affiliate hereby warrants that he/she/it has obtained and will maintain in force all necessary registrations, authorisations, consents and licenses to enable the Affiliate to fulfil his/her/its obligations in terms of this Agreement.
16. Disclaimer
Hatsy makes no representation that the operation of the Website will be uninterrupted or error-free and Hatsy will not be liable for the consequences of any interruptions or errors.
17. Indemnity
17.1.The Affiliate is solely responsible for any marketing initiatives the Affiliate conducts, including, without limitation, compliance of such initiatives with the applicable legal requirements
17.2.The Affiliate hereby indemnifies and holds Hatsy, its associates, officers, directors, employees, agents, shareholders and partners (the "Indemnified party") harmless from and against any and all losses, demands, claims, damages, costs, expenses (including without limitation consequential losses and loss of profit, reasonable legal costs and expenses and VAT thereon if applicable) and liabilities suffered or incurred, directly or indirectly, by the Indemnified party in consequence of any breach, non-performance or non-observance by the Affiliate of the obligations or warranties on the part of the Indemnifying party contained in this Agreement, or any applicable laws or regulations.
18. Exclusion of Liability
18.1.Hatsy shall not be liable for any loss of revenues, profits, contracts, business or anticipated savings, or any loss of goodwill or reputation, or any indirect or consequential losses in any case, whether or not such losses were within the contemplation of the parties at the date of this Agreement, or any other matter under this Agreement.
18.2.The liability of Hatsy shall not, in any event, exceed the sum of the total monies paid by Hatsy to the Affiliate for the period of 6 (six) months preceding the date on which the liability allegedly accrued.
19. Term
19.1.This Agreement shall commence on the date on which the Affiliate is notified that the application to be a participant has been successful. The Agreement shall continue indefinitely thereafter, unless terminated by either party on 30 (thirty) days written notice to the other.
19.2.In the event that the Affiliate breaches its obligations in terms of this Agreement, then Hatsy may terminate this Agreement with immediate effect, and cease to make payment of any further amounts due, owing and payable to the Affiliate.
20. The Affiliate’s Personal Information
20.1.The Affiliate hereby consents to Hatsy’s processing of his/her/its personal information.
20.2.Hatsy undertakes to:-
20.2.1. utilise the information only for the purposes for which it was gathered;
20.2.2. take all reasonable steps to ensure the safekeeping of such information, so as to prevent, insofar as is possible, the unauthorised disclosure of same and/or corruption and/or the loss of same;
20.2.3. process the information only with the knowledge and authorisation of the Affiliate;
20.2.4. not disclose the Affiliate’s personal information to any third parties without the written consent of the Affiliate, unless required by law or in the course of the proper performance of Hatsy’s duties;
20.2.5. have due regard to the generally accepted information security practices and procedures which may apply to the Affiliate generally or be required, in terms of specific industry or professional rules and regulations;
20.2.6. notify the Affiliate immediately where there are reasonable grounds to believe that the Affiliate’s personal information has been accessed or acquired by any unauthorised person;
20.2.7. establish and maintain security measures to secure the integrity and confidentiality of the Affiliate’s personal information in its possession or under its control by taking appropriate, reasonable, technical and organisational measures to prevent loss of, damage to, or unauthorised destruction of the Affiliate’s personal information and unlawful access to, or processing of the personal information, and shall take reasonable measures to:-
20.2.7.1. identity all reasonably foreseeable internal and external risks to the personal information in its possession or under its control;
20.2.7.2. establish and maintain appropriate safeguards against the risks identified;
20.2.7.3. regularly verify that the safeguards are effectively implemented; and
20.2.7.4. ensure that the safeguards are continually updated in response to new risks or deficiencies in previously implemented safeguards.
21. Domicilia and Notices
21.1.The parties to this Agreement hereby select their respective domicilia citandi et executandi for all purposes in terms of this Agreement and/or any claim arising pursuant hereto as follows:-
21.1.1. Hatsy:
Physical address: 47 Thembi Place
15 Calderwood Road
Lonehill
Postal address: P.O. Box 46851
Roosevelt Park
2129
E-mail: affiliates@topbet.co.za
21.1.2. The Affiliate:
The Affiliates chosen domicilium details are reflected on the form to which these terms and conditions are annexed.
21.2.Any notice addressed to a party at its physical or postal address shall be in writing and shall be delivered by hand or sent by pre-paid registered post.
21.3.Any notice shall be deemed to have been given:-
21.3.1. if delivered by hand, on the date of delivery;
21.3.2. if posted by pre-paid registered post, 5 (five) days after the posting thereof;
21.3.3. if transmitted by facsimile or e-mail, on the date of successful transmission.
22. Breach
Unless stipulated herein that Hatsy is entitled to terminate this Agreement immediately, should either party breach any term or condition of this Agreement and fail to remedy such breach within 7 (seven) business days written notice to do so, then the aggrieved party shall be entitled to enforce specific performance of this Agreement, alternatively to cancel this Agreement and to claim damages, entirely without prejudice to such other rights as the aggrieved party may have in law.
23. Miscellaneous
23.1.Entire Agreement
This Agreement contains all of the express provisions agreed on by the parties with regard to the subject matter hereof and the parties waive the right to rely on any alleged express prevision not contained herein.
23.2.Severability
23.2.1. Each of the provisions contained in this Agreement shall be construed as independent of every other such provision, so that if any provision of this Agreement shall be determined by any competent authority to be illegal, invalid or unenforceable, then such determination shall not affect any other provision of this Agreement, all of which other provisions shall remain in full force and effect.
23.2.2. If any provision of this Agreement shall be determined to be illegal, invalid or unenforceable, but would be legal, valid and enforceable if amended, the parties shall consult together in good faith and agree the scope and extent of any modification or amendment necessary to render the provision legal, valid and enforceable so as to give effect as far as possible to the intention of the parties as recorded in this Agreement.
23.3.No Representation
Neither party may rely on any representation which allegedly induced that party to enter into this Agreement, unless the representation is recorded in this Agreement.
23.4.Variation, cancellation and waiver
No contract varying, adding to, deleting from or cancelling this Agreement and no waiver of any right under this Agreement or term hereof, shall be effective unless reduced to writing and signed by or on behalf of the parties.
23.5.Indulgences
No indulgence granted by a party shall constitute a waiver or abandonment of any of that party’s rights under this Agreement and accordingly that party shall not be precluded as a consequence of having granted that indulgence from exercising any rights against the other party which may have arisen in the past or which may arise in the future under this Agreement.
23.6.Cession/Delegation
Except as set out in this Agreement, no party may cede that party’s rights or delegate that party’s obligations without the prior written consent of the other party.
23.7.Jurisdiction
The parties agree to the non-exclusive jurisdiction of South Gauteng High Court, Johannesburg (Republic of South Africa) in respect of any proceedings arising out of in connection with this Agreement.
Palsar Capital Limited, henceforth referred to as “We” “Our” “Us” provides an affiliate programme to promote our clients on whose behalf We administer and manage the affiliate program. In this policy “affiliate” “you” and “your” refers to the individual entity that has agreed to promote the brands we provide marketing services for, in accordance with this Privacy Policy.
This Privacy Policy is designed to help you understand how we collect, use and safeguard your information.
This privacy policy should be read in conjunction with the Affiliate Programmes Terms and Conditions. By entering into any kind of contract with Palsar Capital Limited, you agree to the contents of this privacy policy. If you do not agree with any section of this privacy policy, you should not attempt to use our service.
The Data Controller is Palsar Capital Limited t/a Raven of Glassworks, 1 Back Turner Street, Manchester, M4 1FR
All queries in regards to this privacy policy should be addressed to the Data Protection Officer at the above address, who can also be contacted directly at compliance@raventrack.com
We collect and process the following data from (and about) you:
We implement effective processes to identify, manage, monitor and report risks and internal control mechanisms. These controls include secure systems and networks, and clear processes for privilege access rights. All data is stored securely.
Our lawful basis for processing personal data include:
We may disclose your personal data to:
All processing of information will be governed by the appropriate data protection laws.
We will not send promotional or direct marketing, inclusive of email, SMS, or automated calls, without first obtaining your specific consent.
The consent requires a positive Opt-In either in electronic format, verbally or in writing. The consent will be clear and specific, granular, separate from other Terms and Conditions, name any third parties relying on the consent, and be easily withdrawable.
We will not transfer Personal Data to recipients in Third Party countries that are outside of the EEA, or are not currently recognised by EU law as having an adequate level of legal protection for the rights and freedoms of data subjects unless:
You may request that your Personal Data be anonymised in the following circumstances:
We will only retain data for the necessary time to complete the task that the data was collected for, or to meet our legal obligations.
You are entitled to a file a Subject Access Request (SAR) to obtain a copy of the personal information which we hold about you. If you wish to receive a copy of this information, please contact your account manager, or the DPO directly, and allow up to thirty calendar days for the information to be collated and provided to you. Please note that your identity will need to be confirmed in order to complete a SAR, which may include the disclosure of other personally identifiable documentation in order to prove your identity (such as a passport scan, or valid proof of address) before commencing with the process.
By using the Raven website, you consent to our use of ‘cookies’. A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. We use cookies and the information gained from them to analyse site usage, with this information used accordingly to improve our content and site layout and to remember your onsite preferences.
If you prefer, you can disable cookies in your web browser. The ‘help’ menu on the menu bar of most browsers will have a functionality to disable cookies.
Palsar Capital Limited do not use any automated systems in order to make decisions regarding your account which have any legal effect on You.
Please let us know if you are unhappy with how we have used your personal information in writing to the Data Protection Officer, who will be able to assist further with your complaint or concern. You also have the right to complain to the Information Commissioner’s Office.
This Privacy Policy is kept under continued review by Palsar Capital Limited and can be amended by Us at any time, and without notice to you. Whenever a change is made to the privacy policy which will affect your rights as a data subject, or change the intended processing purposes, then you will be notified directly and asked to agree to the new privacy policy. If you disagree with the changes made to the privacy policy, you retain the right to withdraw consent for future processing, as stated in the introduction to this policy.
This version of the Privacy Policy is effective as of September 20th 2018.