Terms of Use for iForm4U

Last Updated: 27 September 2024

These Terms of Use ("Terms") govern your access to and use of the iForm4U service ("Service"), operated by Privote.net sp. z o.o. ("Company," "we," "us," or "our"). iForm4U is a Software-as-a-Service (SaaS) platform that provides an online form-building tool for both personal and business use. The Service operates on a recurring subscription model, with monthly and yearly plans available. By accessing or using the Service, you agree to be bound by these Terms. If you do not agree to these Terms, you must not use the Service.

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1. Acceptance of Terms

By creating an account, subscribing, or using iForm4U, you agree to be bound by these Terms, our Privacy Policy, and any other policies referenced herein. These Terms apply to both individual consumers ("Users") and business entities ("Companies").

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2. Eligibility

You must be at least 18 years old or possess the legal capacity to enter into a binding contract to use the Service. If you are using the Service on behalf of a Company, you represent and warrant that you have the authority to bind that entity to these Terms.

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3. Subscription Plans and Billing

iForm4U operates on a recurring subscription model, offering both monthly and yearly plans. Subscription fees vary based on the plan selected and whether you are a User or a Company.

3.1 Recurring Billing

• Automatic Renewal: By subscribing, you authorize iForm4U to automatically charge your selected payment method at the beginning of each billing cycle (monthly or yearly) for the applicable subscription fee, including any applicable taxes such as VAT, GST, or sales tax.

• Billing Cycle: Your subscription will automatically renew unless canceled prior to the renewal date. The billing date corresponds to the date you initially subscribed.

• Invoices and Taxation: Invoices will be issued electronically after each payment, reflecting your billing address and customer status (Private Consumer or Company). VAT may apply based on the user's location and status, as required by Council Directive 2008/9/EC for EU business users who do not provide a valid VAT number. Failure to provide accurate information regarding VAT status will result in VAT being applied to your subscription fees.

•  Taxes will be applied based on applicable laws and regulations:

  • European Union: VAT will be charged according to the Council Directive 2006/112/EC on the common system of value added tax ("EU VAT Directive"). Companies with a valid VAT identification number may be exempt under the reverse charge mechanism as per Article 196 of the EU VAT Directive.

  • United Kingdom: VAT will be applied in accordance with the Value Added Tax Act 1994.

  • United States: State and local sales taxes may apply based on your billing address, as required by relevant state laws.

  • Australia: Goods and Services Tax (GST) will be applied pursuant to the A New Tax System (Goods and Services Tax) Act 1999.

  • Similar local tax regulations for other countries.

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3.2 Payment Currencies

Payments may be made in Euro (EUR), US Dollar (USD), or Polish Zloty (PLN). If you choose to pay in a different currency, the amount will be automatically converted to one of the above-listed currencies, depending on the payment provider's exchange rates.

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3.3 Price Changes

iForm4U reserves the right to modify subscription fees. Any price changes will be communicated to you in advance, and the new rates will apply at the start of your next billing cycle. If you do not agree with the new pricing, you must cancel your subscription before the changes take effect.

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4. Acceptable Use of the Service

4.1 Anti-Spam and Communication Consent

You are strictly prohibited from using iForm4U to send unsolicited communications ("spam") to recipients who have not explicitly consented to receive such messages. You agree to comply with all applicable anti-spam laws and regulations, including but not limited to:

• European Union: General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and the ePrivacy Directive (Directive 2002/58/EC).

• United Kingdom: Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR).

• United States: Controlling the Assault of Non-Solicited Pornography And Marketing Act of 2003 ("CAN-SPAM Act").

• Canada: Anti-Spam Legislation (CASL).

• Australia: Spam Act 2003 (Cth).

• Similar laws in other jurisdictions.

Failure to comply may result in immediate termination of your account under Section 5.2 and may subject you to civil and criminal penalties.

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4.2 Ownership and Use of Content

You are solely responsible for all content, including but not limited to text, images, photos, graphics, and videos ("Content"), that you upload or use within the Service. By uploading or using Content, you represent and warrant that:

• You own all necessary rights, licenses, and permissions to use the Content.

• The Content does not infringe upon any third-party intellectual property rights, privacy rights, or other legal rights.

• The Content complies with all applicable laws and regulations.

iForm4U reserves the right to remove any Content that violates these Terms or is deemed inappropriate at our sole discretion.

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5. Subscription Management

5.1 Upgrades and Downgrades

• Upgrading: You may upgrade your subscription plan at any time. The additional fees will be prorated for the remainder of your current billing cycle and charged immediately.

• Downgrading: You may downgrade your subscription, which will take effect at the end of your current billing cycle. No refunds or credits will be issued for downgrades.

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5.2 Subscription Termination

• By You: You may terminate your subscription at any time through your account settings. Termination will take effect at the end of your current billing period. You will retain access to the Service until that time.

• By iForm4U: We reserve the right to suspend or terminate your account immediately if:

  • You violate these Terms.

  • We are unable to process your payment.

  • Your use of the Service is deemed illegal or harmful.

Upon termination, your data may be permanently deleted. It is your responsibility to back up your data prior to termination.

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5.3 Data Retention

• For users with an active paid subscription, data will be retained for the duration of the active subscription.

• For accounts without a paid subscription or free accounts without any user activity, data will be retained for three (3) months. After this period, we reserve the right to delete your data. You will be notified before any deletion of data.

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5.4 Refunds

• Exclusion of Cooling-Off Period for EU Consumers: Pursuant to Article 16(m) of the Consumer Rights Directive 2011/83/EU, the right of withdrawal (cooling-off period) does not apply to digital content not supplied on a tangible medium if the performance has begun with the consumer's prior express consent and acknowledgment that they lose their right of withdrawal.

  By subscribing to iForm4U and accessing the Service immediately, you expressly consent to the commencement of performance and acknowledge that you lose your right of withdrawal.

• Refunds for Companies: Refunds are not available for Companies unless required by applicable law.

• General Refund Policy: No refunds will be issued for unused portions of your subscription after the billing cycle has commenced.

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6. License and Restrictions

iForm4U grants you a limited, non-exclusive, non-transferable, and revocable license to access and use the Service for your internal business or personal purposes, subject to these Terms.

You agree not to:

• Modify, copy, or create derivative works based on the Service.

• Resell, sublicense, or transfer the Service to any third party.

• Use the Service for any unlawful or unauthorized purposes.

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7. Data Ownership and Privacy

You retain ownership of all data you submit through the Service. By using iForm4U, you grant us permission to store, process, and transmit your data as necessary to provide the Service.

Your personal data will be handled in accordance with our Privacy Policy and applicable data protection laws, including:

• European Union: General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

• United Kingdom: Data Protection Act 2018 and UK GDPR.

• United States: Relevant federal and state laws, including the California Consumer Privacy Act (CCPA).

• Australia: Privacy Act 1988 (Cth) and the Australian Privacy Principles.

• Similar laws in other jurisdictions.

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8. Service Availability and Support

We strive to provide continuous access to the Service but do not guarantee uninterrupted availability. Maintenance, upgrades, or unforeseen issues may occasionally affect access.

Support is available via [Email/Phone] during [Support Hours].

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9. Limitation of Liability and Disclaimers

9.1 No Warranties

The Service is provided "as is" and "as available" without warranties of any kind, either express or implied. iForm4U does not warrant that the Service will be uninterrupted, error-free, or free from viruses or other harmful components.

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9.2 Limitation of Liability

To the maximum extent permitted by applicable law, iForm4U shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, data, or other intangible losses, resulting from:

• Your access to or use of the Service.

• Unauthorized access to or alteration of your transmissions or data.

• Any conduct or content of any third party on the Service.

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10. Indemnification

You agree to indemnify and hold harmless iForm4U, its affiliates, officers, directors, employees, and agents from any claims, damages, liabilities, losses, or expenses (including reasonable attorneys' fees) arising out of or in connection with:

• Your violation of these Terms.

• Your use of the Service.

• Your violation of any applicable laws or regulations.

• Your infringement of any third-party rights, including intellectual property rights.

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11. Governing Law and Dispute Resolution

• These Terms are governed by and construed in accordance with the laws of the jurisdiction in which the Company is based, which is Poland, EU.
  

• Any disputes arising from or related to these Terms shall be subject to the exclusive jurisdiction of the courts located in Poland, EU.

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12. Changes to Terms

We reserve the right to modify these Terms at any time in accordance with applicable laws. We will notify you of any material changes by posting the new Terms on our website and updating the "Last Updated" date. Your continued use of the Service after such changes constitutes your acceptance of the new Terms.

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13. Contact Information

If you have any questions or concerns about these Terms, please contact us at:

• Email:
• Contact form: https://iform4u.com/contact
• Address: S.Staszica 33, 05-822 Milanówek, Poland (EU).

iform4u privacy policy

This is the privacy notice of privote.net sp. z o.o. registered in the Register of the District Court for the Capital City of Warsaw, Commercial Court, Commercial Division of the National Court Register under KRS number: 0000911319, tax identification number NIP 5291836147  (‘we’, ‘our’, or ‘us’).
privote.net sp. z o.o., is an legal owner of iform4u brand.

Our registered office is at S.Staszica 33, 05-822 Milanówek, Poland (EU).

Introduction

This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

Personal data we process

1. How we obtain personal data

The information we process about you includes information:

• you have directly provided to us
• that we gather from third party databases and service providers
• as a result of monitoring how you use our website or our services

2. Types of personal data we collect directly

When you use our website, our services or buy from us, (for example, when you create an account on our website), we ask you to provide personal data. This can be categorised into the following groups:

• personal identifiers, such as your first and last names and your title
• contact information, such as your email address, your telephone number and your postal addresses for billing, delivery and communication
• account information, including your username and password
• payment type information (we do not collect debit or credit card number and expiry date and bank account details)
• records of communication between us including messages sent through our website, email messages and telephone conversations
• marketing preferences that tell us what types of marketing you would like to receive

3. Types of personal data we collect from third parties

We confirm some of the information you provide to us directly using data from other sources. We also add to the information we hold about you, sometimes to remove the need for you to provide it to us and sometimes in order to be able to assess the quality of the services you offer.

The additional information we collect can be categorised as follows:

• information that confirms your identity
• business information, including your business trading name and address, your company number (if incorporated), and your VAT number (if registered)
• information that confirms your contact information
• reviews and feedback about your business on other websites through which you sell your services
• unsolicited complaints by other users

4. Types of personal data we collect from your use of our services

By using our website and our services, we process:

• your username and password and other information used to access our website and our services
• information you contribute to our community, including reviews
• your replies to polls and surveys
• technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
• usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
• transaction information that includes the details of the products services you have bought from us and payments made to us for those services
• your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.

5. Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of our website is useful.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

6. Special personal data

Special personal data is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

We do not collect any special personal data about you.

7. If you do not provide personal data we need

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract.

In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

The bases on which we process information about you

If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

8. Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal data.

We may use it in order to:

• verify your identity for security purposes when you use our services
• sell products to you
• provide you with our services
• provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

9. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal data.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at or contact form on https://iform4u.com/contact. However, if you do so, you may not be able to use our website or our services further.

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.

10. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• improving our services
• record-keeping for the proper and necessary administration of our business
• responding to unsolicited communication from you to which we believe you would expect a response
• preventing fraudulent use of our services
• exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
• insuring against or obtaining professional advice that is required to manage organisational or business risk
• protecting your interests where we believe we have a duty to do so

11. Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal data.

12. Information we process to protect vital interests

In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal information on the basis of vital interests.

For example, we may inform relevant organisations if we have a safeguarding concern about a vulnerable person.

How and when we process your personal data

13. Your personal data is not shared

We do not share or disclose to a third party, any information collected through our website.

14. Information you provide

Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

For example, when you leave a review or post a message on our website, we reasonably assume that you consent for the message to be seen by others. We may include your username with your message, and your message may contain information that is personal data.

Other examples include:

• tagging an image
• clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

In posting personal data, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We do not specifically use this information except to allow it to be displayed or shared.

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal data that you have posted. You can make a request by contacting us at or contact form on https://privote.net/contact .

15. Payment information

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of  PayPal or Stripe. That page may be branded to look like a page on our website, but it is not controlled by us.

16. Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

17. Information obtained from third parties

Although we do not disclose your personal data to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal data from third parties whose services we use.

No such information is personally identifiable to you.

18. Credit reference

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

19. Disputes between users

In the event of a dispute between you and another user, provided that you consent, we may share your basic personal data, business information and contact information with the other user.

At our discretion, we may share other information to enable the dispute to be resolved through litigation or alternative dispute resolution methods.

20. Service providers and business partners

We may share your personal data with businesses that provide services to us, or with business partners.

As examples:

• we may use fraud prevention agencies and credit reference agencies to verify your identity and we may pass your information to those agencies if we strongly suspect fraud on our website
• we may pass your contact information to advertising agencies to use to promote our services to you

21. Referral partners

This is information given to us by you in your capacity as an affiliate of us or as a referral partner.

It allows us to recognise visitors that you have referred to us, and to credit to you commission due for such referrals. It also includes information that allows us to transfer commission to you.

The information is not used for any other purpose.

We undertake to preserve the confidentiality of the information and of the terms of our relationship.

We expect any affiliate or partner to agree to reciprocate this policy.

Use of information we collect through automated systems

22. Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.

We use cookies in the following ways:

• to track how you use our website
• to record whether you have seen specific messages we display on our website
• to keep you signed in to our website
• to record your answers to surveys and questionnaires on our site while you complete them
• to record the conversation thread during a live chat with our support team

23. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.              

24. Re-marketing

Re-marketing involves placing a ‘tracking technology’ such as a cookie, a ‘web beacon’ (also known as an ‘action tag’ or a ‘single-pixel GIF’) to track which pages you visit and to serve you relevant adverts for our services when you visit some other website.

The benefit of re-marketing technology is that we can provide you with more useful and relevant adverts, and not show you ones repeatedly that you may have already seen.

We may use a third-party advertising service to provide us with re-marketing services from time to time. If you have consented to our use of such tracking technologies, you may see advertisements for our products and services on other websites.

We do not provide your personal data to advertisers or to third-party re-marketing service providers. However, if you are already a member of a website whose affiliated business provides such services, that affiliated business may learn of your preferences in relation to your use of our website.

Other matters

25. Your rights and obligations

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at this document.

You obliged to share full, true and up-to-date personal data.

You have right to:

• access the content of their personal data,

• correct/supplement their personal data,

• delete their personal data,

• limit the processing of these data,

• raise an objection to the processing of these data,

• transfer data,

• file a complaint with a supervisory authority,

• revoke consent at any time without impact on compliance with the law of processing (if processing occurs on the grounds of the consent).

You may exercise the aforementioned rights by:

• contacting us by email ;
• contact form on https://privote.net/contact
• contacting us by a registered letter or courier parcel sent to: S.Staszica 33, 05-822 Milanówek, Poland (EU).;

26. Use of our services by children

We do not sell products or provide services for purchase by children, nor do we market to children.

27. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

28. Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

At any time, you may contact us to request that we provide you with the personal data we hold about you.

At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.

To obtain a copy of any information that is not provided on our website you should contact us to make that request.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

If you wish us to remove personally identifiable information from our website, you should contact us to make your request.

This may limit the service we can provide to you.

We remind you that we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

29. Communicating with us

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.

We may keep personally identifiable information associated with your message, such as your name, phone no. and email address so as to be able to track our communications with you to provide a high quality service.

30. Complaining

If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.

When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.

We aim to investigate all complaints relating to user generated content. However, we may not be able to do so as soon as a complaint is made. If we feel that it is justified or if we believe that the law requires us to do so, we shall remove the content while do so.

Making a complaint may not result in the removal of the content. Ultimately, we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

If your complaint reasonably requires us to notify some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

• to provide you with the services you have requested
• to comply with other law, including for the period demanded by our tax authorities
• to support a claim or defence in court

31. Compliance with the law

Our privacy policy complies with the law in the EU specifically with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32016R0679

Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

32. Review of this privacy policy

We shall update this privacy notice from time to time as necessary.