Twactiva Privacy Policy - How we deal with data
This site and services all exist to inform and contribute. Twactiva is a labour of love.
Twactiva considers your privacy, freedom and an open internet in the development of each of our projects, site and services - meaning that privacy is IMPORTANT to us and we are dedicated to be transparent and open and to protect the privacy and security of the visitors/users of the site and services. Our transparent and open community-based platform promotes mutual participation, our accountability and your trust.
Twactiva does not, currently, serve advertisements and does not sell user information to third parties, Twactiva has also taken unique steps that help you control how much user information is shared, when you use the site and services.
Introduction
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Introduction
We have prepared this Privacy Policy to provide transparency for our practices and principles and to explain how we collect, use, and share information you provide online.
Please read the following terms and policies carefully in their entirety, to inform yourself, as they explain the Twactiva privacy practices. Needless to say, we are dedicated to treating your personal information with care and respect.
By using the site and services, you consent to such use of your information and ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THE POLICIES, TERMS, AND CONDITIONS SET FORTH HEREIN.
Unless otherwise noted, on a particular site and services, this Privacy Policy applies to your use of all site and services that Twactiva operates, as well as the products and information provided through the site and services.
Please note, that this policy applies only to sites and services maintained by Twactiva and not to any authorized sponsors, the sites and services operated by affiliates of Twactiva and sites and services maintained by other companies or organizations, to which we link or from which we aggregate content.
This Privacy Policy applies only to the practices of companies/foundations we own, manage, or are united with under common control. In addition, this Privacy Policy does not govern our use of any information you provide to us when you call us, write to us, or communicate with us in any manner other than through the site and services. In addition, as the Internet is global, any user information that we may collect or that you submit may be transferred to, processed in, and held in countries (including The Netherlands) other than the one in which you reside.
We follow this privacy policy in accordance with local laws, in the places where we operate.
If you have questions or concerns, please contact Twactiva. Note: Apart from what is written and included in this Privacy Policy, we would only share your information, when we have asked and received your permission to share.
Privacy Policy List
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- Information Twactiva may collect and how/when we share it.
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Unlike many other free online services, Twactiva does NOT, curently, make money from selling advertising on the site and via its services, serving ads to you, or selling user information about our users to third parties, including advertisers, data brokers, search engines, or anyone else. We may use your user information in ways for which you have given us permission and may share your user information, including personal identifying information, with third parties ONLY under several circumstances, including:
If you tell us, it is OK, to do so. If we believe that we need to do so to comply with applicable law or legal obligations. Please also see the section "Law Enforcement / Other Disclosures" If Twactiva should have an affiliated company. Twactiva does not have any affiliated companies right now but, if we do, in the future, we may share user information with them, too. If we contract with a third party service provider to offer services for you '” for example, with a credit card processing company, if you decide to buy something through the site and services. Please also see the section "Authorized Sponsors" and/or "Service Providers"
- User information - What information do we talk about
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(A) 'Personal Identifiable Information' (info you submit) You can visit the site and services without telling us who you are or revealing any user information, by which someone could personally identify you (which we will refer to in this Privacy Policy collectively as "Personal Identifiable Information"). If, however, you wish to register to become a contributor, you may be required to provide certain 'Personal Identifiable Information' (e.g. your name and e-mail address), and we will ask that you also provide a password. We use your 'Personal Identifiable Information' to fulfil your requests for projects and services, to improve our services, and to contact/update you about our projects and services.
(B) 'Non-Personal Information' (info you submit) Any user information that falls outside of this 'Personal Identifiable Information' is automatically termed "Non-Personal Information." You may also choose to submit additional user information about yourself (for example your gender, birth date, etc.), by which someone could not personally identify you (info which we will also refer to in this Privacy Policy collectively as 'Non-Personal Information').
(C) 'Non-Identifiable Information' (info we Automatically Collect) To help us understand how our users use the site and services, we may also collect additional user information, when you visit certain features of the site and services or the pages of certain of our partners when you interact, when you contact us for support, when you log into the site and services with your account, when you complete a survey or when you enter campaigns or promotions, etc. In these cases, we may collect and store general, "Non-Identifiable Information" about what pages you access, your general geographic location (e.g. a country or city, but not a street address), the device you are using, an anonymized version of your IP address, the Web page you came from, the URL you go to next, and the Web page(s) that you access during your visit. We may use this user information to protect Twactiva and its users from spam, viruses, identity theft, illegal or harmful activities, as well as to understand how people use the site and services, which features work and which don't, and to help us develop and improve the site and services' features and services. For example, if we create a feature that everybody is using, we will want to know about that, so we collect data about how many different features are used. We may create anonymous, Non-Identifiable Information, records by excluding 'Personal Identifiable Information' (such as your name) from records.
(D) 'Publicly Shared Information' (which you submit) Finally, you may choose to submit your alias, bio, email, photos or any other user information that you would like to share with other users of the site and services (which we will refer to in this Privacy Policy collectively as "Publicly Shared Information"). Among other things and functionality, the site and services and areas of the site and services, are platforms with the purpose of publicly posting and sharing content (e.g. message boards, discussion rooms, and other online forums and communication) that will be available to all, or some, other users of the site and services. By choosing to use these areas, you understand and agree that anyone may access, use, and disclose any user information that you post and should assume that anything you publicly post or upload on the site and services, other than private messages, will be accessible by the public. In addition, search engines will be able to see the content you post. Personal content that you post may be copied, shared, or re-posted on the site and services and on other parts of the Internet in ways that you and we cannot control. We have made it easy for you to delete any posted content from your personal account, and also to delete your account altogether (there's a link to do so on your personal settings page). However, we may store backups of your content on our servers, even after it is deleted or after you delete your account. Furthermore, deleting your account or specific content doesn't mean that your content hasn't been copied or shared on the site and services, and on other parts of the internet by people or services that have nothing to do with the site and services. We strongly suggest that you consider this when deciding what to post and what not to post on the site and services (or anywhere on the Internet, for that matter). Please post responsibly! Note: if we store your 'Personal Identifiable Information' with 'Non-Personal Information', we will consider the combination as 'Personal Identifiable Information'. In addition, if we remove all Personal Information from a set of data, then, the remaining is back to 'Non-Personal Information'. Our primary goals in collecting 'Personal Identifiable Information' are to provide you with the projects and services made available through our web site and services, including, but not limited to, our services, to communicate with you and to manage your registered user account, if you have one. Except as otherwise described in this section of our Privacy Policy, we will never share your 'Personal Identifiable Information', 'Non-Personal Information', Non-Identifiable Information, or 'Publicly Shared Information' with any third party without your permission.
(E) Information from social networking site and services (you authorize and submit). When you interact with our site and services and services through various social media, such as when you login through Facebook, or share content on Facebook, Twitter, Pinterest, Instagram or other site and services, we may receive information from the social network, including your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. For inspirational purposes, we may use your Friends data to let you know what your Friends are doing on our site and services, and to let your Friends know what you are doing on the site and services. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites before linking or connecting them to our site and services.In addition and, of course, with your permission, Twactiva may access your contact list available on your mobile device or in your email accounts in order to invite your friends and contacts to connect with our site and services.
- About the information we collect.
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To fulfil its mission, Twactiva depends on the participation of people like you. The site and services are designed to facilitate that participation through interaction, which often means asking people for their personal information. We use this information to operate, maintain, and provide to you the features and functionality of the site and services, as well as to communicate directly with you, such as to send you email messages and push notifications, and permit you to communicate with others on the site and services or on social media. We may also send you site and services-related emails or messages (e.g., account verification, confirmations, change or updates to features of the site and services, technical and security notices). For more information about your communication preferences, see your personal settings on your profile page. What follows is an explanation of examples and ways in which we ask for your user information, what is protected and what isn't. So, you can get an idea of some situations we are talking about.(A) Registration We aim to invite you to register at the site and services and become a contributor, as this is the first and main purpose of the site and services. If you do not register, you may not be able to help contribute to the cause. If you desire to have access to certain restricted sections of the site and services, you will be required to become a registered user, and to submit certain 'Personal Identifiable Information' to us. 'Personal Identifiable Information' that we may collect in such instances may include your name, password, email address, city, time zone, telephone number, and other user information that you decide to provide us with or that you decide to include, in your public profile, in order to contribute successfully. If you register, you agree to provide true, accurate and complete information about yourself, as you value the importance of freedom, being (true to) yourself, honest and authentic. You also agree to update registration information that you provide, to maintain its truth, accuracy and completeness. We may also collect personal information, if you contribute to campaigns or projects, including text, sounds, photographs, audio, video, images, graphics and other content or materials. Information you post will be viewable to the public. You control how much Personally Identifying Information you wish to provide in your public profile. We also collect information about how you use the site and services, including projects you join/follow, interests, and interaction with others on the site and services, and user content you post to the site and services in the form of messages, comments, likes, shares, and other content. We do not share, or otherwise disclose, any 'Personal Identifiable Information' collected in this process. Only Twactiva staff and authorized sponsors (as described further below) have access to 'Personal Identifiable Information' provided by you. For all optional fields, of course, you have the choice as to whether to provide such information to us and to which extend.
(B) Password and Security If you register, you will be asked to provide a password, which you should keep secure and secret. You are responsible for maintaining the confidentiality of your password to access the site and services, and you are solely liable and legally responsible for all activities that occur under your password, whether or not made with your knowledge or authority. You agree to immediately notify us of any unauthorized use of your password or any other breach of security related to the site and services. If you suspect that someone may have obtained your password, you should change your password, instantly. We reserve the right to require you to alter your password, if we believe that your password is no longer secure. YOU AGREE THAT WE WILL NOT BE LIABLE FOR ANY LOSS OR DAMAGE ARISING FROM YOUR FAILURE TO ADEQUATELY SAFEGUARD YOUR PASSWORD. If anyone ever contacts you and asks for your password, they are probably trying to scam you. Twactiva will never do this. Please don't give your password to anyone. Please, let us know about such events.
(C) Direct Contact
The site and services have online form(s) and email addresses, through which you can contact us with questions and concerns, to report problems with the site and services or other issues. In order to respond to you, we need your email address and country in which you live. While we retain this user information for our records, we will not use it for any purpose except to correspond with you. You may also use these online form(s) and email addresses to correspond with us if you have any questions regarding any rights you may have or this Privacy Policy and with our knowledge, we will do our best to help and answer you as soon as possible.
- Authorized Sponsors
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On occasion, we may need to share some of your 'Personal Identifiable Information' with our selected authorized sponsors. For example, external (sponsored) contractors working to maintain and develop the site and services for the sole purpose of helping us do our work. However, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law. They all have signed a non-disclosure agreement and abide by the requirements in this Privacy Policy and the way Twactiva deals with data and will not share your 'Personal Identifiable Information' or use it for any purpose other than for the benefit of (improving) the Twactiva mission. You can learn more about the authorized partners, with whom we work and what options they may offer you regarding cookies and/or targeted advertising on our sponsor page '¢ Third party vendors, consultants and other service providers that perform services on our behalf, in order to carry out their work for us, which may include identifying and serving targeted advertisements, accepting payments, content or service fulfilment, or providing analytics services.
- Service Providers
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From time to time, we may enter into relationships with certain trusted third parties (third party vendors, consultants and other service providers), who perform functions on our behalf and provide services to us, including, without limitation, e.g., hosting and maintenance, customer relationship, database storage and management, direct marketing campaigns and storage services, providing analytics services or credit card processing services. In those circumstances, we disclose user information that is necessary for such service providers to perform those services and we require that they maintain the confidentiality of such user information. We will share your 'Personal Identifiable Information' with these third parties, but only to the extent necessary to perform these functions and provide such services. However, these companies are prohibited from using your personal information for purposes other than those requested by us or required by law. They all have signed a non-disclosure agreement and abide by the requirements in this Privacy Policy and the way Twactiva deals with data and will not share your 'Personal Identifiable Information' or use it for any purpose other than for the benefit of (improving) the Twactiva mission. These service providers could very well include third parties at your request. For example, you may have the option to share your activities on Twactiva with your friends through email or on various social media site and services. You can learn more about the service providers, which we work with and what options they may offer you regarding cookies and/or targeted advertising, etc. on our page
- Law Enforcement / Other Disclosures
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We will do our best to refuse unmotivated legal requests to access user information. However, we may disclose your user information or content as necessary, in order to comply with any applicable law, regulation, legal process, enforceable governmental request or governmental order. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any user information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims, legal process (including subpoenas), to protect the property and rights of Twactiva or a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity or to comply with the law. Provided we have collected and retained an email address for you, Twactiva will use reasonable means to notify you promptly of an event, if we are going to release your user information, unless, by law, we are prohibited from or otherwise advised not to notify you, on the advice of legal counsel. When we receive requests like this, we'll only release your 'Personal Identifiable Information', if we have a good faith belief that the law requires us to do so. Nothing in this policy is intended to limit any legal defences or objections that you may have to a third party's request to disclose your user information. If we think that, by disclosing your user information, we may prevent serious harm to Twactiva, its staff, users, you, or anyone else for that matter, we may do so without notifying you, in order to protect our rights, reputation and property or that of our users, affiliates, or the public. Finally, we may disclose your user information, if we believe it is necessary to detect, prevent, or otherwise address safety, fraud, or security concerns related to Twactiva. Other Disclosure Scenarios In contrast with anything in this Privacy Policy, we reserve the right, and you, hereby, expressly authorize us, to share any user information:
In response to subpoenas, court orders, or legal process, or to establish, protect, or exercise our legal rights or defend against legal claims If we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the safety of any person or property If we believe it is necessary to investigate, prevent, or take action regarding significant abuse of the site and services' infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of user information) To any parent company, subsidiaries, joint ventures, or other companies under common control with us (in which case, we will require such entities to honour this Privacy Policy) If we are acquired by, or merged with, another entity. If our organizational structure or status changes (if we undergo a restructuring, are acquired, or go bankrupt) we may pass your user information to a successor or affiliate.
- Cookies
- Opt-Out/Updates/notifications
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In addition, from time to time, we may email you information about Twactiva that we think is necessary and important and provide you with information/updates about our projects and services. By opening or maintaining an account with Twactiva, you agree to receive administrative emails, as part of your basic service. You can always opt-out of non-administrative emails. If you decide, at any time, that you no longer wish to receive such information or communications from us, we offer you the opportunity to choose not to receive or adjust the amount of content communications from us. If you would like to take advantage of this opportunity, please let us know by accessing and updating your profile and adjusting your profile notifications or follow the unsubscribe instructions provided in any of the communications or within your profile environment. In the profile environment section of your IAMTwactiva Hero account, you can make choices about how your data is used and shared. We are frequently adding new features and controls, so visit it often and configure your account to fit your up-to-date personal preferences regarding privacy, data collection, and data sharing. Please note, that, sometimes, these requests may take up to a few weeks to process and that we are not responsible for removing user information from the database of any third party, to whom we were authorized to disclose your user information, prior to processing your request. Even if you do take advantage of this opportunity, we reserve the right to send you administrative messages relating to the site and services (e.g., about changes to this Privacy Policy) and to contact you regarding any goods or services you may have ordered.- Data storage, Modifying and Deleting accounts and data.
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You can access or change your personal profile and contact information or delete your account altogether through your personal settings page. Note, if you choose to delete, instead of deactivate your account, you can no longer retrieve your content or reactivate your account and we cannot do so for you. If you would like to modify or delete, from our database, any user information that you previously submitted to us, please let us know by accessing and updating your profile. Please note that any user information that we have copied may remain in back-up storage for some period of time after your request, and that if you delete certain user information, you may not be able to use/order services in the future without re-submitting such user information. Also, please note that we will maintain user information in our database, whenever we are required to do so by law. Twactiva stores its data on servers run by third parties. We, or a third party we work with, may keep backups of Twactiva's data and code, which may or may not include posts and other user information that you have placed on the site and services, even after you have deleted your account. Therefore, even after you delete your account, your data may remain in backups on our system, although it will be no longer visible or publicly accessible on the site and services. As a service provider, Twactiva could technically access your web-based account, tied to our site and services and could log in, on behalf of any of its users, to any of the accounts they have accessed using our site and services. Twactiva will never use this technical login ability for any purpose but testing/troubleshooting unless otherwise required by law.- Security, Integrity and Retention
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The site and services and services may contain links to other websites not owned or controlled by us. We are not responsible for the privacy practices and we cannot control the activities of such other websites. We encourage you to be aware when you leave our site and services and urge you to review/consult the respective privacy policies of these third-party websites and practices prior to submitting any user information to such websites. You should always consult the respective privacy policies of these third-party websites that may collect your personal information.
- Security, Integrity and Retention
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The site and services and services are hosted in The Netherlands. Please note, that your personal data may be located on servers in The Netherlands. By providing your personal data, you consent to the use of your personal data for the uses identified, above, in accordance with the Privacy Policy. To locate and host the Amsterdam-based, Twactiva, in The Netherlands is a very conscious/ (well thought through?) choice. The Netherlands scores number one Twactiva and the Dutch government was one of the first to accuse Google of violating data privacy laws. While the US government is encouraging such anti-privacy measures, the Netherlands has EU privacy laws as well as its own provisions to provide websites with excellent privacy. It is no surprise that the Netherlands is ranked second in Freedom of the Press, behind only Finland. There are actual examples of how Dutch web hosting companies forced the government to provide them legal paperwork for taking a website down, and the government backed off. Of course, the Netherlands' location in Europe makes it an excellent choice for pure geographic reasons, but one of the highest privacy standards in Europe doesn't hurt, either. In addition, Amsterdam/The Netherlands has always been exemplarily Twactiva and can continue to do so now that we are on board and will spread this very freedom to inspire others across the globe.- Children
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The site and services is intended for the general public, but not for children under 13. If you are under 13, we don't want your Personal Identifying Information, and you must not provide it to us. We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children's online activities and interests. The site and services are not intended for, and may not be used by, children under the age of 13. If you use the site and services, you hereby represent and warrant that you are at least 13 years of age. We do not knowingly contact or collect Personal Identifying Information from children under the age of 13 and we do not target the site and services to children under the age of 13. It is possible that by fraud or deception, we may receive user information pertaining to children under 13. If we are notified of this, we will, immediately, obtain parental consent or otherwise delete the user information from our servers. If you are a parent or guardian and believe that your child who is under 13 has provided us with Personal Identifying Information or if you become aware that a child under the age of 13 is using the site and services, or has posted Personal Identifying Information about themselves on the site and services, please contact us to have your/a child's user information removed.
- Security, Integrity and Retention
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As a premium participation platform and campaigner community Twactiva, Twactiva realizes the importance of security and takes its responsibility to its users extremely seriously. To that end, we have made internal efforts to help us to ensure the security of our site and services, services and any data provided to us by our users, at all times. We are committed to protecting your Personal Identifying Information, once we have it. We have implemented a variety of reasonable, industry-standard security, technologies and procedures designed to help protect your user information from loss, abuse, or unauthorized access or disclosure. We use encryption technologies when transferring and receiving data from the site and services. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. So, despite all of our security measures, you should know that we couldn't fully eliminate security risks associated with information and mistakes may happen. The transmission of information over the Internet is never completely secure, so, while we do our best to protect information, we cannot guarantee its security. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications. Yet, if we learn of a security breach, we will post a reasonably prominent notice to the site and services so that you can take appropriate protective steps. We also do not want your information for any longer than we need it, so we only keep it long enough to do what we collected it for. Once we don't need it, we take steps to destroy it unless we are required by law to keep it longer.- (Crowd)-testing
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That said, neither our software nor the internet, in which we operate, is static. Just as we have crowd-sourcing, crowd-creating, crowd-funding, etc., we also fully applaud crowd-testing. It's great to have our users test us from time to time to keep us sharp, especially if they put in addition time and effort to also help to improve any critical points that may have risen. Therefore, we want you to feel free and comfortable using our site and services and we want you to share any suspicions, whatsoever, you may have. You would be doing us a service if you let us know if we overlooked something. Again, all together, we can make this work!Furthermore, Twactiva welcomes the assistance of the security community. Especially, we appreciate help in finding vulnerabilities and bugs in Twactiva's technology and interface. If you are a security specialist and find a vulnerability, please let us know right away. Please note, however, that while doing your research you may not destroy or hurt Twactiva, harm the performance of the site and services, or violate the privacy of our users, their accounts, and data. As long as you work within the boundaries of these rules and our policies, we are grateful for your help. When willing to contribute to the cause, as mentioned above, please abide to the rules below.(A) Investigation Rules
- Always contact us prior to any testing and await our confirmation before taking any action. When investigating suspected security vulnerabilities, users must target their own accounts. Unauthorized access of another user's account or private data is forbidden. Do not use automated testing tools or initiate attacks that could impact the reliability or integrity of our services (port scanning, fuzzing, denial of service attacks, etc). Investigation should be limited to services on Twactiva domains. Targeting our third party vendors is not allowed. Violations of these rules will result in account suspension and/or IP banning or even more serious consequences.
(B) Reporting Suspected Vulnerabilities All vulnerabilities or security concerns should be reported by email to This email address is being protected from spambots. You need JavaScript enabled to view it.. We encourage the use of our PGP key <idea??>to send encrypted mail. Please provide as detailed an explanation of the vulnerability as possible (including reproduction steps and/or examples), so that we can evaluate and respond as quickly as possible.
(C) Our Response The product team will review the submitted report and create a case, in our issue tracking system. You will receive a response via email outlining the next steps in the process and regular updates from us as we investigate and/or fix the issue.To protect our users, we ask that you not publicly discuss the issue until we have addressed the reported vulnerability.
- Updates
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From time to time, we may need to change this policy and our notices. If, under any such update, we make any material change to the way in which we treat your user information, we will inform you of such change. The updates will be posted online. Any updated version of this Privacy Policy will be effective, as of the date set forth therein. To make your review more convenient, we will revise the Effective Date above. We encourage you to, periodically, review this Privacy Policy to stay informed about how we are protecting the personal information we collect. Your continued use of the product or service, after the effective date of such changes constitutes your acceptance of such changes and updates. If you do not agree with the upcoming change, please delete your account and mention your reason and points, on which you might disagree. You can also always find the most current version of this policy on our web site and services.- Questions, Comments & Complaints
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If you have any comments or questions about this Privacy Policy, or feel that they could be better, please feel free to contact us. We warmly welcome your freedom-fostering feedback. If you believe your personal information has been abused or handled in such a manner contrary to the policy stated above, please contact us.