coin policy

 

Privacy Policy

Effective Date: February 24, 2026

Your privacy is important to us.  This privacy policy explains the personal information that we collect, how we process it, and for what purposes.  It also explains how you can access and control your personal information.  

We offer various products, services, websites, applications, and devices, all of which are referred to as “service” or “services” in this policy.  Many services allow users to leverage location technology, such as the Coin mobile app available at https://coinapp.co, the personal location beacons, and the location-based blockchain network at https://xyo.network.  

Please read this privacy policy carefully. It applies to the services mentioned above, as well as to any other of our services that display this policy. By purchasing or using any of our services, you are accepting and consenting to the practices described in this policy.

1.  Personal Information We Collect

Personal information is information about you or your use of our services that can be used to identify you. When you interact with our services, we may collect some personal information about you or your use of the services. You provide some of this information directly, such as your name and email address when creating an account, or your name, payment information and delivery address when purchasing a service. We may also collect personal information when you use our services, such as your location when using our geolocation software on a mobile device. The information we collect depends on the nature of your interactions with us and the choices you make, including your mobile phone permissions and browser settings. We may also obtain personal information about you from third parties we work with, such as website analytics providers or advertising networks.

We rely on a variety of legal reasons to process personal information, such as with your consent, the necessity to enter into or perform contracts, to comply with legal obligations, or to balance legitimate interests, for a variety of purposes described below.

We protect personal information obtained from third parties according to the practices described in this policy, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time and include advertising networks, such as Facebook, Google and YouTube, and website analytics providers, such as Google Analytics.

You have choices when it comes to the services you use and the information you share. When we ask you to provide personal information, you may decline. In many instances, we require some of your personal information in order to provide the service. If you choose not to provide information necessary to provide you with a particular service, you cannot use that service. Likewise, where we need to collect personal information by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing service you are using, we may have to suspend or cancel it. We will notify you if this is the case at the time.

Personal information we collect can include the following:

  • Name and contact information. Your name, email address, postal address, phone number and other similar contact data.
  • Credentials. User name, password, password hints, and similar security information used for authenticating and accessing our services.
  • Other identifiers. Account number, unique user identification number, advertising identifiers, user names and aliases from third party services, such as social media, and other similar online identifiers.
  • Demographic. Information about you such as your age, gender, country and state of residence, and preferred language.
  • Financial. Information for processing payments from you, such as your credit or debit card number, bank account number, and the security code associated with your account.
  • Commercial. Information about the items you purchase, the services and features you use and interact with, your licenses and subscriptions to our services, the activities associated with your account, and your interactions with us.
  • Device and usage. Information about your computer, mobile phone or other device used to access and use our services, such as your IP address, unique device identifiers, mobile carrier, device type, configuration, software, settings, browsing history, referral URLs, cookies, files, metadata, and other similar information about the hardware, software, and connectivity of your device.
  • Mobile device data.  If you install our mobile application on your device, certain information and data on your device will be accessible by us in accordance with your mobile device permission settings, such as geolocation data, contacts, and other system tools.
  • Geolocation data. Information about your real-world geographic locations, including through the use of GPS, nearby cell towers, and Wi-Fi hotspots.  Please note that our location-based network and mobile applications require users to provide their geolocation data.
  • Token issuance. If you are issued tokens to use on our network, we will collect information sufficient to validate your eligibility, verify your identity, and comply with our internal procedures and applicable law, including, for example, a government issued identification number such as a tax number, driver’s license number, or personal identification number.
  • Performance data. Information about the performance of our services and any problems you experience, including error reports containing details about your device software and hardware.
  • Customer support.  When you contact us for inquiries or technical support, we collect information that allows us to categorize, investigate, and respond to your inquiry, as well as track potential problems and trends, and customize our support responses to better serve you.  Please note that any phone conversations, online chat sessions and other communications with us may be monitored and recorded.
  • Content consumption data.  Information about media content you access through our services, such as news or information articles, or video or audio recordings, available on our website or other service.
  • Searches and commands.  Search queries and commands when you use our services with search or related productivity functionality.
  • Social data. Information about your relationships and interactions between you, other people, and organizations, such as types of engagement (likes, dislikes, etc.) related to people and organizations.
  • Interests and favorites.  Data about your interests and favorites, such as products, services and features you like or dislike using.  In addition to those you explicitly provide us, your interests and favorites can also be inferred or derived from other data we collect.
  • Contacts and relationships. Data about your contacts and relationships if you use our service to communicate or share information with others, or refer others to use our services.
  • Feedback and surveys. Information you provide to us and the content of messages you send to us, such as feedback, survey data, and product reviews you write.
  • Content or other input. Any other information, text, data, files, communications, images, audio, video or other content or inputs provided by you when using our services or interacting with us, such as the content of your messages to us, and any data, documents, images, software or other media you upload, store, retrieve or otherwise process within our services.
  • Inferences.  Inferences made about your preferences, interests, behavior and characteristics based on any of the above information.

2.  How We Use Personal Information

When we process personal information about you, we do so with your consent or as necessary to provide the products and services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests, as described in this section and in the Reasons We Share Personal Information section of this policy.  

More specifically, we use the personal information we collect to:

  • Provide our services and administer your use of them, which includes updating, securing, troubleshooting, and providing support. It also includes sharing information when it is required to provide the service or carry out the transactions you request, such as providing your financial information to our payment processor.
  • Improve and develop our services.
  • Personalize your experience with our services, including by making inferences about your interests and interactions with the services to provide more relevant products, content, and features.
  • Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you relevant offers.
  • Notify you about changes to the services.
  • Contact you regarding important updates or feature announcements, or to obtain feedback from you regarding the services.
  • Fulfill any other purpose we may describe when you provide the information.

  • Fulfill any other purpose with your consent.

  • Ensure proper functioning of our location-based network, the tokens that operate on the network, and other related services.

  • Operate our business, which includes analyzing our performance and conducting research.

  • Comply with legal obligations.  For example, we use the age of our customers to ensure we meet our obligations to protect children’s privacy. We also process contact information and credentials to help customers exercise their data protection rights.
  • Enforce or apply our terms of service or other agreements, including for billing and collection purposes.
  • To protect the rights, property, or safety of our employees, customers or others, or to prevent any activity we may consider to be a risk of being illegal, unethical, inappropriate or legally actionable.

For users in North America, some of our apps may share your device’s precise geolocation and other details about your device (like hardware characteristics, a variety of sensor data, and a list of installed third-party applications) with our partner Sense360 on an ongoing basis, including when the apps are closed. This information is sent with the device’s advertising identifier or another unique device-specific code. Sense360 may use all of this information to generate surveys for users, for market research and other research regarding aggregated patterns, and as further described in its Privacy Policy (https://sense360.com/privacy-policy/), which has more detail on the entire process. For example, Sense360 analyzes restaurant visit trends to better serve its customers’ needs. You can use your device settings to (i) disable or limit precise geolocation collection for the entire device (which will affect some device functionality) or just particular apps (which may affect the functionality of this app) and/or (ii) disable or limit use of the advertising identifier (which will block that identifier’s transmission to Sense360).

We use advertising/technology services from a third party called inMarket which may use device and location data to provide advertisements for and anonymous analytics to goods and services likely to be of greater interest to you. To see inMarket’s full privacy policy, please visit http://www.inmarket.com/privacy_policy.html

Location data is shared with third parties, including Foursquare, for their own purposes such as for analytics and targeted advertising purposes. Details about Foursquares privacy pactices and privacy policies can be found in their Foursqaures Privacy Center under https://location.foursquare.com/legal/privacy-center/

and location data is also shared back from Foursquare to us for our own use cases and features.

In return for extra daily rewards in the COIN app, you may choose to be a peer on the Bright Data network. By doing so you agree to have read and accepted the Terms of Service of the Bright SDK EULA: https://bright-sdk.com/eula. You may opt out of the Bright Data network by unchecking the enabled checkbox on the Bright Data Screen (accessible from Rewarded Tasks).

See the SDK Privacy Policy at https://bright-sdk.com/privacy-policy for further information.

3.  Reasons We Share Personal Information

We share your personal information with your consent or as necessary to complete any transaction or provide any service you have requested, accessed, or authorized. When you provide payment information to make a purchase, we will share it with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction. We also may disclose personal information as part of a corporate transaction, such as a merger or sale of assets, and we may disclose personal information to any subsidiaries or affiliate companies that we control.

We share personal information with service providers or agents working on our behalf for the purposes described in this policy. We may employ individuals and third party companies to facilitate, enhance or secure the services, to provide the services on our behalf, to assist us in analyzing how the services are used (such as website analytics), and to perform functions related to administration of the services (such as hosting, maintenance, and database management).  Our service providers include:

  • Google. We use Google for usage statistics and analytics to help us measure traffic and usage trends for the services. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, and other data that assists us in improving the services. We may collect and use this analytics data together with your personal information and other data to build a broader profile of our individual users so that we can serve you better.  You can find out more information about how Google collects and processes data here (https://policies.google.com/technologies/partner-sites).  

Our service providers are not allowed to use personal information they receive from us for any other purpose. Please note that the links to our third-party service provider’s privacy policies and the information contained within them may change from time to time, and the links provided above may not be current. If the links provided do not allow you to access the privacy policies, please notify us by sending us an email at privacy@xylabs.com.

Pursuant to your consent, we also share your personal information, including precise location data and device identifiers with Foursquare Labs, Inc to support our own use cases and features,. Foursquare may also use such data for their own purposes, such as for location-based analytics and targeted advertising. Details about Foursquares privacy practices and privacy policies can be found in their Foursquare's Privacy Center under https://location.foursquare.com/legal/privacy-center/. You can opt-out of having your location data shared with our business partners and other third parties by visiting https://my.coinapp.co/settings and clicking the "Do Not Sell or Share My Personal Information" link.

In addition, we will retain, access, transfer, disclose, and preserve personal information when we have a good faith belief that doing so is necessary to do any of the following:

  • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
  • Protect our customers and users, such as preventing spam or attempts to defraud our users, or to help prevent the loss of life or serious injury to anyone.
  • Operate and maintain the security of our services, including preventing any attacks on our computer systems or networks.
  • Protect our rights or property, including enforcing our terms of use and referring appropriate matters to law enforcement.

Please note that some of our services include advertisements and links to services of third parties whose privacy practices differ from ours. Personal information provided by you to any of those third parties is governed by their privacy policies.

We do not share, sell, rent or disclose your personal information to third parties for the third parties’ direct marketing purposes.

4.  Your California Privacy Rights

Residents of California have certain privacy rights under the California Consumer Privacy Act of 2018 (CCPA).  This section describes those rights and how you may exercise them.

Access.  You have the right to request what personal information we have collected, used, disclosed and sold about you during the previous 12 months.  This includes the categories of personal information and sources of origin, the business or commercial purpose for collecting or selling personal information, categories of third parties with whom we share personal information, and the specific pieces of personal information collected.

Deletion.  Subject to certain exceptions, you have the right to request that we delete your personal information.  Please be aware that deleting your personal information is irreversible, and you will no longer have an account with us, including any tokens or credits in your account.  We may not delete your personal information if any of the following exceptions applies:

  • To complete a transaction, provide goods or services, or perform a contract.
  • To detect security incidents and protect against fraudulent or illegal activity.
  • To debug or repair errors.
  • To comply with legal obligations and exercise legal rights.
  • For internal use in a lawful manner compatible with the context it was provided.

Opt-Out.  You have the right to opt-out of the sale of your personal information.  Please note that while we do not sell any of your personal information to third parties in exchange for money, we do share some information with third parties in order to provide better services and personalized advertising to you, and such sharing may constitute a “sale” of personal information under the CCPA.

Non-Discrimination.  We will not discriminate against you for exercising any of your rights under the CCPA.

Exercising Your Rights.  To submit a privacy related request, you may email us at privacy@xylabs.com or call us at +1 (866) 200-5685.  Prior to processing, we will verify your request using standard verification procedures, such as verifying the information provided in your request with your account information we have in our records.  Please allow up to 45 days to complete your request.  Please note that your California privacy rights are subject to exceptions, and in certain cases we may decline your request as permitted by law.

Authorized Agents.  If you wish to designate an authorized agent to submit a privacy related request on your behalf, you must provide the authorized agent with written permission to do so, and your authorized agent must submit such written permission with your request.

Shine a Light Inquiry.  Separate from the CCPA, California residents may, under California’s “shine the light” law, request from companies doing business in California that they have an established business relationship with, a list of personal information shared by those companies with third parties for the third parties’ direct marketing purposes during the preceding year.  We do not disclose your personal information to third parties for the third parties’ direct marketing purposes.

Categories of Personal Information Collected and Shared in the Past 12 Months

This section summarizes the categories of personal information of California consumers that we collected over the past 12 months, and the categories of third parties with whom we shared this information.  The categories of sources of this personal information include you, your device hardware and software used to interact with us and our services, and the other sources listed in the Personal Information We Collect section of this policy.  To better understand the business or commercial purposes for collecting this personal information, please review the How We Use Personal Information section of this policy.  The categories of third parties with whom this personal information is shared includes financial institutions, service providers, government authorities, and other entities listed in the Reasons We Share Personal Information section of this policy.

Categories of personal information collected in the past 12 months:

  • Identifiers
  • Financial
  • Characteristics of protected classes
  • Commercial
  • Internet activity
  • Geolocation data
  • Audio, visual and electronic
  • Inferences

We may not collect each of these categories about every consumer.  For example, credit card information (Financial) would only be collected from California consumers who use a credit card to make a purchase from us.

Categories of personal information sold in the past 12 months:

  • Identifiers
  • Characteristics of protected classes
  • Commercial
  • Internet activity
  • Geolocation data
  • Inferences

Please note that while we do not sell any of your personal information to third parties in exchange for money, the CCPA’s definition of “sale” is broad and encompasses common sharing practices, such as sharing data with third parties to display personalized advertising.

Categories of personal information disclosed for a business purpose in the past 12 months:

  • Identifiers
  • Characteristics of protected classes
  • Commercial
  • Internet activity
  • Geolocation data
  • Inferences

5.  Cookies and Similar Technologies

Cookies are small data files saved to a user’s device that track, save and store information about the user's online interactions and usage. This allows each website, through its servers, to provide the user with a tailored experience within the website.  This data often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well.  Some cookies are placed by third parties acting on our behalf.  We use cookies and similar technologies such as web beacons to store and honor your preferences and settings, enable you to sign-in, provide interest-based advertising, combat fraud, analyze how our services perform, and fulfill other legitimate purposes described below.  

Our use of cookies and similar technologies

We use cookies and similar technologies for several purposes, depending on the context or service, including:

  • Storing your preferences and settings. We use cookies to store your preferences and settings on your device, and to enhance your experiences. Saving your preferences with cookies, such as your preferred language, prevents you from having to set your preferences repeatedly.

  • Sign-in and authentication. We use cookies to authenticate you. For example, when you sign in to a website using your account, we store a unique ID number and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page within the site without having to sign in again on each page. You can also save your sign-in information so you do not have to sign in each time you return to the site.

  • Security. We use cookies to process information that helps us secure our services, as well as detect fraud and abuse.

  • Storing information you provide to a website. We use cookies to remember information you shared. When you provide information to us, we store the data in a cookie for the purpose of remembering the information.

  • Social media. Some of our websites may include social media cookies, including those that enable users who are signed in to the social media service to share content via that service.

  • Feedback. We use cookies to enable you to provide feedback on a website.

  • Interest-based advertising. We use cookies to collect data about your online activity and identify your interests so that we can provide advertising that is most relevant to you.

  • Displaying advertising. We use cookies to record how many visitors have clicked on an advertisement and to record which advertisements you have seen, for example, so you don’t see the same one repeatedly.

  • Analytics. We use first- and third-party cookies and other identifiers to gather usage and performance data. For example, we use cookies to count the number of unique visitors to a web page or service and to develop other statistics about the operations of our services.

  • Performance. We use cookies to understand and improve how our services perform. For example, we use cookies to gather data that helps with load balancing which helps ensure that our websites remain up and running.

In addition to the cookies set by us when you visit our websites, our third-party service providers can also set cookies when you visit our sites. For example:

  • Companies we hire to provide services on our behalf, such as website analytics, place cookies when you visit our sites.

  • Companies that deliver content on our websites and applications, such as videos (e.g. YouTube), articles or advertisements, place cookies on their own. These companies use the data they process in accordance with their privacy policies, which may enable these companies to collect and combine information about your activities across websites, apps, or online services.

How you can control cookies

Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. Please refer to your browser's privacy or help documentation to find instructions for blocking or deleting cookies.

Certain features of our services depend on cookies. If you choose to block cookies, you may not be able to sign in automatically or use some of those features, and preferences that are dependent on cookies will be lost. If you choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, are deleted and will need to be recreated.

Additional privacy controls that can impact cookies are described in the How to Access and Control Your Personal Information section of this Policy.

Our use of web beacons and analytics services

Some of our services, such as our websites, contain electronic tags known as web beacons that we use to help deliver cookies on our websites, count users who have visited those websites, and deliver co-branded products. We also include web beacons or similar technologies in our electronic communications to determine whether you open and act on them.

In addition to placing web beacons on our own websites, we sometimes work with other companies to place our web beacons on their websites or in their advertisements. This helps us develop statistics on how often clicking on an advertisement on our website results in a purchase or other action on the advertiser's website.

Finally, our services may contain web beacons or similar technologies from third-party analytics service providers, which help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations. These technologies enable the analytics providers to set or read their own cookies or other identifiers on your device, through which they can collect information about your online activities across applications, websites, or other products.

Other similar technologies

In addition to standard cookies and web beacons, our services can also use other similar technologies, such as browser, device, digital and other fingerprinting to identify your device.

6.  How to Access and Control Your Personal Information

This section describes certain steps you can take to access and control your personal information that we have obtained, and manage your communications with us.  California residents can also exercise the rights described in the California Privacy Rights section of this policy.  

European Users

European-based users of our services who are subject to the European Union’s General Data Protection Regulation (GDPR) have certain rights, including:

  • Withdrawing consent to use your personal information, if providing such consent was the basis of our use of your information.
  • Requesting a portable copy of your personal information.
  • Requesting the rectification or erasure of your personal information.
  • Opting-out of our use of your personal information for marketing, sales or non-service-related purposes.

These rights are subject to certain exceptions and limitations. If you wish to exercise any of your rights under the GDPR, you may do so by sending us an email at privacy@xylabs.com.  

Opting out of emails and mobile notifications

If you receive promotional emails or SMS messages from us and would like to opt out, you can do so by following the directions in that message, such as selecting the “unsubscribe” link at the bottom of the email and following the opt-out instructions. Notifications from our mobile applications can be turned off using the notifications controls in your mobile device.

Please note that opting out of these communications will not apply to mandatory service communications that are part of certain services or other informational communications that have their own unsubscribe method.

Opting out of certain targeted advertising

You can opt out of receiving certain targeted ads by visiting the following third-party websites:

Browser-based controls

When you use a web browser, you can control your personal information using certain features, such as:

  • Cookie controls. You can control the data stored by cookies and withdraw consent to cookies by using the browser-based cookie controls described in the Cookies section of this policy.
  • Tracking protection. Your browser may allow you to control the data third-party sites can collect about you using tracking protection tools built into the browser, or by downloading third-party browser extensions or plugins that limit tracking.
  • “Do Not Track.” Some browsers have incorporated a “Do Not Track” feature that sends a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret this signal, our services do not yet respond to browser Do Not Track signals.

Updating or correcting your account information

You may update or correct your online or mobile account information by logging into your account and navigating to the “My Account” or similar page on our website or mobile application, or by emailing us at privacy@xylabs.com.

 

7.  Data Security

How We Secure Personal Information

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as a credit card number or password) over the internet, we protect it through the use of encryption. We also comply with applicable data protection laws, including applicable security breach notification laws.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the services, you are responsible for keeping this password confidential. We ask you not to share your password(s) with anyone.

Where We Store and Process Personal Information

We primarily store data about you, including personal information, on servers located and operated within the United States.  Therefore, if you reside outside of the United States, in order to provide the services to you, we may send and store your personal information outside of the country where you reside or are located, to the United States.  Our collection and use of your personal information is therefore subject to the laws of the United States related to privacy and data protection, in addition to laws in your country that may still apply.  If applicable laws in your country of residence are more protective than U.S. law, we adhere to the requirements of those more protective laws.  For example, when we transfer personal information out of the European Economic Area, we use appropriate safeguards (including standard contractual clauses approved by the European Commission, where applicable) to help ensure that your rights and protections travel with your data.

In some cases, the information we collect from you will be stored on our servers.  In other instances, the information we collect about you may be stored on servers owned and operated by trusted third party providers we have contracted with.  Our agreements with those providers require them to restrict use of your personal information to that which there is a legal basis for, and to employ reasonable security measures that are at least as stringent as those we use to protect your information from unauthorized access.

Our Retention of Personal Information

We retain your personal information for as long as necessary to provide the services you have requested, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types, the context of our interactions with you or your use of our products, actual retention periods can vary significantly.

Other criteria we use to determine the retention periods include:

  • Is a user’s account for receiving services considered to be active?  We will retain your information for as long as your account is active, as needed to provide the services you have requested, unless you request that we delete your personal information.  Deactivation of your account does not mean that your personal information has been deleted from our database entirely in certain circumstances, such as if we deem retention necessary to comply with legal obligations or protect our legitimate interests or those of others.

  • Do users provide, create, or maintain the data with the expectation we will retain it until they affirmatively remove it? In such cases, we would aim to maintain the data until you actively delete it.
  • Is there an automated control that enables the user to access and delete the personal data at any time?  If there is not, a shortened data retention time will generally be adopted.
  • Is the personal information of a sensitive type?  If so, a shortened retention time would generally be adopted.

  • Have we adopted and announced a specific retention period for a certain data type? If so, that retention period would be applied to that data time.

  • Has the user provided consent for a longer retention period? If so, we will retain data in accordance with your consent.
  • Does a legal, contractual, or similar obligation require us to retain or delete the information? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or information preserved for the purposes of litigation. Conversely, if we are required by law to remove unlawful content, we will do so.

Our Use of Blockchain Technology

The unique value of our location-based network derives from the use of a public, Ethereum-based blockchain to verify and record transactions made with our network tokens. Although the information recorded in this manner through our network will, to the extent practicable, be minimized and “anonymized”, the nature of blockchain technology may require certain data considered to be personal information, such as location data, to become permanently stored and inaccessible to any requests for deletion or correction by users.  Please do not use our location-based network if you do not wish to permanently store any data using blockchain technology.

8.  Collection of Information From Children

Our services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.  If we learn we have obtained personal information about a child under 13 without verification of parental consent, we will delete that information. Individuals under 18 years of age are not permitted to use the service.  If you believe we might have any personal information about a child without parental consent, please contact us at privacy@xylabs.com.

9.  Changes to This Policy

We update this policy when necessary to provide greater transparency or in response to:

  • Feedback from customers, regulators, industry, or other stakeholders.
  • Changes in our services.
  • Changes in our data processing activities.

When changes to this privacy policy are made by us, we will revise the Effective Date set forth at the beginning of this policy. If there are material changes to this policy, such as a change to the purposes of processing of personal information that is not consistent with the purpose for which it was originally collected, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this policy.

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