Privacy Policy

TreeSolution Security Awareness AG (hereinafter “TreeSolution Security Awareness AG”, “we” or “us”) undertakes to process all personal data (hereinafter “personal data”) collected via the portal in accordance with Swiss data protection law and to take appropriate security measures to protect it from unauthorized access. In this data protection declaration, we inform you in particular about which personal data is collected and processed in connection with the use of the portal, for what purposes it is used, to whom it may be passed on and what your rights are in connection with the use of your personal data by TreeSolution Security Awareness AG. Personal data means any information relating to an identified or identifiable natural or legal person, e.g. surname, first name, address, e-mail address, date of birth or phone number.

By accessing the online portal (hereinafter “portal” or “website”) and using the services and products we offer, you declare that you have read this privacy policy carefully and agree to the data processing described. Any questions in connection with this privacy policy can be sent at any time by e-mail to info@treesolution.com. If you do not agree with this declaration, you must refrain from accessing the portal and using our services and products.

1. Who is responsible for your personal data

The controller within the meaning of data protection legislation is TreeSolution Security Awareness AG, Bösch 23, CH-6331 Hünenberg, phone: +41 58 510 98 00, e-mail: info@treesolution.com.

TreeSolution Security Awareness AG determines the purposes and means of the processing of your personal data and is therefore responsible for the processing and use of your personal data in accordance with this privacy policy. If you have any questions or concerns about this Privacy Policy or the processing of your personal data, please contact us at any time by sending an e-mail to info@treesolution.com.

2. How do we process personal data

All personal data collected via the website is processed in compliance with the Swiss Data Protection Act. We collect and process personal data carefully and for the purposes described in this Privacy Policy. In compliance with applicable law, we may also use your personal data in ways other than described in this Privacy Policy. In this case, we will provide you with specific privacy policies or notifications at the time of collection and obtain your consent, if necessary. We undertake every reasonable effort to collect information in anonymized or pseudonymized form so that we cannot recognize your identity.

3. What personal data do we collect and for what processing purposes

3.1 Personal data transmitted automatically via the use of the portal

TreeSolution Security Awareness AG collects and stores information that your browser automatically transmits to us in “server log files” when you visit our website. You express your will and interest in visiting our website and the resulting data collection is based on our legitimate interests in operating the website. This may include the following data:

  • Browser type and browser version;
  • Used operating systems;
  • Referrer URL (the previously visited website);
  • Host name of the accessing computer;
  • Date and time of the server request;
  • Internet Protocol address (IP address);
  • Transferred data volume;
  • Other similar data and information used for hazard prevention in the event of attacks on our IT systems.

This personal data will not be merged with other personal data and will be stored separately from any other personal data submitted by the user.

TreeSolution Security Awareness AG uses the automatically collected personal data to fulfill the following purposes:

  • Enabling the display, operation and functionality of the portal;
  • Ensuring the stability and security of the system;
  • Improving and protecting our services;
  • Statistics in the event of attacks on the network infrastructure on which the website is made available.

3.2 Personal data that the user submits to us

TreeSolution Security Awareness AG collects and processes personal data that the user voluntarily submits to TreeSolution Security Awareness AG through an online form directly on the portal, by contacting us by e-mail, through any other applications connected to the portal, by telephone or in any other way. This information includes, for example, the following personal data:

  • Surname, first name, postal addresses, e-mail address, telephone number, gender;
  • your message or inquiry.

The provision of this personal data is expressly on a voluntary basis. Without this personal data, however, we will not be able to provide the services requested by the user in the desired quality or at all.

TreeSolution Security Awareness AG uses the personal data submitted by the user to us to fulfill the following purposes:

  • to provide, maintain, protect and optimize the services and information offered;
  • to communicate with you and provide you with the best possible and personalized information you require from us (e.g. about our products and services);
  • to offer you new services and information and, based on your profile, to suggest customized services and information that may be of interest to you;
  • to comply with legal or other regulatory requirements and internal regulations;
  • to enforce, exercise and/or defend actual or potential legal claims, investigations or similar proceedings;
  • for other legitimate purposes, if this processing is evident from the circumstances or was indicated at the time of collection.

4. On what legal basis do we process personal data about you

The processing of this personal data is based on the following legal bases:

  • your consent, but only if it can be withdrawn at any time (e.g. when you subscribe to our newsletter and other marketing communications);
  • for the fulfillment of a contract with you or for the intention to enter into a contract with you (e.g. when purchasing a product);
  • to comply with a legal obligation (e.g. for tax reasons or for the purpose of legal investigations or proceedings) or
  • to safeguard our legitimate interests (e.g. protection and security of our services, systems, assets; compliance with legal, regulatory and contractual obligations; enforcement, exercise or defense of legal claims; maintenance and efficient organization of business operations; improvement and development of our services; and sale and marketing of our services).

If the processing is based on your consent or our legitimate interests, you can withdraw your consent or object to this processing at any time by contacting us directly at info@treesolution.com. Please note, however, that the withdrawal of your consent does not affect the lawfulness of processing based on the consent before its withdrawal.

5. Whom do we share your personal data with

TreeSolution Security Awareness AG takes the necessary measures to ensure that only our authorized personnel and our auxiliary persons who have the necessary knowledge have access to your personal data in order to fulfill the purposes for which your personal data was collected.

We may disclose your personal data to the following possible categories of recipients in accordance with the purposes and legal bases of processing described above, insofar as this is necessary for the intended processing of data:

  • Other companies in the Group;
  • Service providers who process the personal data on behalf of and as instructed by TreeSolution Security Awareness AG (so-called contract processors such as in the areas of IT, hosting and support);
  • Customers, partners, suppliers, insurance companies and other business partners;
  • Media agencies and the public, including visitors to the Group's websites and social media;
  • Industry-related organizations, associations and other bodies;
  • Acquirers or parties interested in acquiring business units, companies or other parts of the Group;
  • Courts, arbitration bodies, law enforcement agencies, regulators, attorneys and other parties to potential or actual legal proceedings where necessary to comply with the law or to enforce, exercise or defend rights or legal claims.

We select our partners and processors carefully and only if we have sufficient guarantees that they have suitable technical and organizational measures in place in accordance with the legal requirements. Our processors are only allowed to process personal data on our documented instructions. They are all subject to confidentiality requirements and may only use your personal data to the extent necessary to fulfill the purpose for which your personal data was collected, unless otherwise required by law.

6. Transfer of personal data to countries outside the EEA

The personal data collected via our website is stored in Switzerland. In addition, we may transfer, store and process your personal data at data locations around the world, e.g. where our third-party providers or partners are located. Therefore, we may transfer your personal data outside the European Economic Area (EEA) if this is necessary for the data processing described in this Privacy Policy in accordance with applicable law.

Where data is transferred to countries that do not ensure an adequate level of protection, we ensure an adequate level of data protection by providing appropriate safeguards, such as contractual safeguards (e.g. based on EU standard clauses), on the basis of binding corporate rules, the transfer of data in accordance with your explicit consent, for the conclusion or fulfillment of a contract with you, or in connection with the establishment, exercise or enforcement of legal claims. For more information about our appropriate security measures, please contact us by email at info@treesolution.com.

7. How long do we keep information about you

In general, personal data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected, unless longer storage is necessary to fulfill legal obligations (e.g. storage and documentation obligations), contractual or pre-contractual obligations or our legitimate business interests (e.g. to enforce, exercise or defend legal claims).

On this basis, we generally process personal data in compliance with the following rules and obligations:

  • The personal data you automatically submit by using our portal (see item 3.1.) for the purpose of displaying, operating and ensuring the functionality of the portal will be deleted within three to six months.
  • The personal data you submit to us in connection with the use of our services and products offered on our portal or which you otherwise submit to us via the e-mail contact address (see item 3.2.) will generally be stored by us until you request us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed).
  • The personal data you submit to us in connection with the use of our services and products offered on our portal or which you otherwise submit to us via the e-mail contact address (see item 3.2.) will generally be stored by us until you request us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed).

8. Cookies, Google services

When you access or use the website, we may place so-called cookies—small text files—or similar tools on your computer. We use these cookies to recognize you as a user of the website, to customize content, to improve the performance of the website and to improve its user-friendliness.

a) Categories of cookies we use

Depending on their function and purpose, the cookies we use can be divided into the following categories: functional cookies, performance cookies and advertising cookies.

  • Functional cookies: These cookies serve a variety of purposes for the presentation, functionality and performance of a website and in particular to improve the experience and enjoyment of visitors to the website. They enable a website to save information already provided (e.g. user name, location or language selection) and provide visitors with improved, more personalized functions. Functional cookies are used, for example, to remember things like your login credentials. These cookies cannot track your movement on other websites.
  • Performance cookies: These cookies are used to collect information about how a website is used—e.g. how you arrived at our website, which pages you opened most frequently, how you navigated our website during your visit and whether you receive error messages from a page. We may also use these cookies to provide us with certain statistical and analytical information, such as how many visitors have visited our website. Those cookies are used to monitor the level of activity on the website and to improve its performance.
  • Advertising cookies allow us or a third party provider to place ads on our website or on third party websites with products that the user likes, so that the ads the user sees may be more relevant to the user's preferences or interests (sometimes referred to as “targeting cookies”). They can also be used to evaluate the effectiveness of advertising and sales promotions.

These cookies may be placed by us or by a third party on our behalf. You will find further information about cookies and their use at: http://www.allaboutcookies.org/.

The legal basis for data processing results from your consent (Art. 6 (1) a GDPR) or our legitimate interest (Art. 6 (1) phrase 1 (f) GDPR). Our legitimate interest arises from

  • processing of personal data within a customer relationship,
  • processing of personal data for direct marketing,
  • processing of personal data from employees or customers,
  • prevention of fraud,
  • ensuring network and information security,
  • disclosure of personal data within a group of companies for “internal administrative purposes”.

You can configure your browser settings so that no cookies are stored on your computer. If you deactivate cookies completely but you may not be able to use all the functions of our website.

By continuing to use our website and/or agreeing to this Privacy Policy, you consent to us placing cookies and thus to personal usage data being collected, stored and used, even beyond the end of the browser session. You are free to revoke this consent at any time by activating the browser setting to refuse third-party cookies.

b) Google Analytics

TreeSolution Security Awareness AG uses the website analysis service of Google Analytics on its website, which is operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The cookies used by Google Analytics are stored on your computer and enable your use of the website to be analyzed.

We use Google Analytics on the basis of our legitimate interests to analyze and regularly improve our website and to use the statistics obtained to regularly improve our range of products and make it more appealing to you. Furthermore, the use of Google Analytics is based on your consent to the tracking of your surfing behavior on our websites and their analytical evaluation.

The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. These cookies may contain the following information, for example: IP address, number of visits, date and time of a visit, duration of a visit, your access page from which you use the website (reference URL), the pages visited on our website, browser type/version and operating system used. Google will use this information on our behalf because we have a legitimate interest in analyzing user behavior so that we can optimize both our website and our advertising. Google will utilize this information to evaluate the use of our website, to compile reports on website activity and to provide us with other services relating to website activity and internet usage. Pseudonymized user profiles may also be created from the processed personal data.

We have extended the function on this website with the code “gat._anonymizeIp();” to ensure anonymized collection of IP addresses (so-called IP masking). This way your IP address will be shortened by Google within member states of the European Union, in other signatory states to the Agreement on the European Economic Area and in Switzerland before being transmitted to the USA. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there.

You can prevent the storage of cookies by selecting the appropriate settings in your browser software. However, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent. You can also prevent the collecting and submitting of personal data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this personal data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout. Alternatively, or with browsers on mobile devices, you can prevent Google Analytics from collecting your personal data by clicking on the following link: Deactivate the collection of personal data by Google Analytics for this website. In this case, a special opt-out cookie will be placed on your device, which prevents the future collection of your user data when you visit the website. If you delete your saved cookies, you must click this link again. For more information on how Google Analytics handles user personal data, please refer to Google's privacy policy: https://support.google.com/analytics/answer/6004245.

Moreover, it is possible that Google may check how the website is used by the user and possibly combine the personal data collected with other information about the user that Google has collected independently from other websites the user had visited and use this for its own purposes (e.g. to control advertising) on its own responsibility on the basis of its own privacy policy. For further information on this and how Google processes personal data please refer to Google's privacy policies: https://policies.google.com/; https://policies.google.com/technologies/partner-sites.

c) List of cookies

Below you will find a complete list of the cookies we use or will use on this website, including information about their use and expiration time.

Provider / cookie name / purpose / duration

  • Cloudflare / __cf_bm / This cookie placed by Cloudflare is used to support Cloudflare Bot Management. / 1 hour
  • TreeSolution / languageRedirected / This cookie redirects the user to a language version of the website according to the language settings of their browser. / 2 days
  • Google / _gcl_au / The Google Tag Manager places this cookie to test the advertising effectiveness of websites that make use of its services. / 3 months
  • Treesolution / alert / Shows a warning strip to the user at the top of the page. / 1 day
  • Google / _ga_* / Google Analytics places this cookie to store and count page views. / 1+ year
  • Google / _ga / The _ga cookie installed by Google Analytics calculates visitor, session and campaign data and also tracks site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. / 1+ year
  • Wonderchat.io / next-auth.csrf-token / This cookie opens the online chat assistant. / Session
  • Wonderchat.io / nextauth.message / Defines properties for the online chat assistant. / never
  • Wonderchat.io / chakra-ui-color-mode / Defines properties for the online chat assistant. / never
  • Wonderchat.io / __Secure-next-auth.callback-url / Defines properties for the online chat assistant. / never
  • Google / rc::a / This cookie is placed by the Google Recaptcha service to identify bots and protect the website from malicious spam attacks. / never
  • Google / rc::c / This cookie is placed by the Google Recaptcha service to identify bots and protect the website from malicious spam attacks. / never

9. Social Media Plug-ins

We use the social media plug-ins below on our website to make our company better known. The underlying advertising purpose is to be considered a legitimate interest within the meaning of Art. 6 (1) f GDPR).

Responsibility for data protection-compliant operation must be guaranteed by the respective provider. Data processing in connection with these plug-ins is carried out with your consent when you use them.

If you use the services of these social networks independently or in connection with our website, the social networks will evaluate how you use the plug-in. In this case, information about the plug-in is forwarded to the social networks.

a) Facebook

Our website uses plug-ins from the social network Facebook, which is operated by Meta Platforms, Inc., 1601 Willow Road Menlo Park, CA 94025, USA. The Facebook plug-ins are marked with a Facebook logo or the addition “Like” or “Share”. You will find an overview of the Facebook plug-ins and their appearance at: https://developers.facebook.com/docs/plugins.

When you access a page on our website that contains such a plug-in, your browser establishes a direct connection to the Facebook servers. The content of the plug-in is transmitted by Facebook directly to your browser and integrated into the page.

Through this integration, Facebook receives the information that your browser has accessed the corresponding page of our website, even if you do not have a Facebook profile or are not currently logged in to Facebook. This information (including your IP address) is transmitted directly from your browser to a Facebook server in the USA and stored there.

If you are logged in to Facebook, Facebook can directly associate your visit to our website with your Facebook profile. If you interact with the plug-ins, e.g. by clicking the “Like” button, this information is also transmitted directly to a Facebook server and stored there. The information will also be published on your Facebook profile and displayed to your Facebook friends.

The purpose and scope of the collected data, their further processing and use by Facebook as well as your rights in this regard and setting options to protect your privacy can be found in Facebook's privacy policy: https://www.facebook.com/privacy/policy/.

b) Google AdWords

This website uses Google Conversion Tracking. If you have reached our website via an advertisement sent by Google, Google AdWords will place a cookie on your computer. The conversion tracking cookie is placed when a user clicks on a Google-served ad. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages on our website and the cookie has not expired, we and Google may recognize that the user clicked on the ad and was redirected to this page. Each Google AdWords advertiser receives a different cookie. Cookies can therefore not be tracked via the websites of AdWords advertisers. The information gathered using the conversion cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Advertisers are told the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users.

If you do not wish to participate in the tracking, you can refuse the required placing of a cookie—for example via a browser setting that generally disables the automatic placing of cookies or sets your browser to block cookies from the domain "googleleadservices.com".

By continuing to use our website and/or agreeing to this Privacy Policy, you consent to us placing cookies and thus to personal usage data being collected, stored and used, even beyond the end of the browser session. You are free to revoke this consent at any time by activating the browser setting to refuse third-party cookies.

c) LinkedIn

We use the marketing services of the social network LinkedIn of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland ("LinkedIn") within our online offer.

These use cookies, i.e. text files that are stored on your computer. This enables us to analyze your use of the website. For example, we can measure the success of our advertisements and show users products in which they were previously interested.

For example, information on the operating system, the browser, the website you previously visited (referrer URL), which websites the user visited, which offers the user clicked on, and the date and time of your visit to our website are recorded.

The information generated by the cookie about your use of this website is transferred pseudonymously to a LinkedIn server in the USA and stored there. LinkedIn therefore does not store the name or email address of the respective user. Rather, the above-mentioned data is only assigned to the person for whom the cookie was generated. This does not apply if the user has allowed LinkedIn to process without pseudonymization or has a LinkedIn account.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also object to the use of your data directly at LinkedIn:  https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

We use LinkedIn Analytics to analyze and regularly improve the use of our website. The obtained statistics enable us to improve our product offer and make it more appealing for you as a user. All LinkedIn companies have adopted the standard contractual clauses to ensure that the data traffic to the USA and Singapore necessary for the development, implementation and maintenance of the services takes place in a lawful manner. If we ask users for their consent, the legal basis for processing is Art. 6 (1) a GDPR. Otherwise, the legal basis for the use of LinkedIn Analytics is Art. 6 (1) p. 1 (f) GDPR.

Information of the third-party provider: LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2 Ireland; User Agreement and Privacy Policy.

d) The SalesViewer® Technology

This website uses SalesViewer® technology from SalesViewer® GmbH on the basis of the website operator's legitimate interests (Art. 6 (1)(f) GDPR) to collect and store data for marketing, market research and optimization purposes.

In order to do this, a javascript based code, which serves to capture company-related data and according website usage. The data captured using this technology are encrypted in a non-retrievable one-way function (so-called hashing). The data is immediately pseudonymised and is not used to identify website visitors personally.

The data stored in the context of Salesviewer will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations.

You can object to the collection and storage of data at any time with effect for the future by clicking on this link https://www.salesviewer.com/opt-out in order to prevent SalesViewer® from recording your data. In this case, an opt-out cookie for this website will be saved on your device. If you delete the cookies in the browser, you will need to click on this link again.

e) YouTube

Functions of the "YouTube" service are integrated on this website. "YouTube" is owned by Google Ireland Limited, a company incorporated and operated under the laws of Ireland with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland, which operates the services in the European Economic Area and Switzerland.

Your legal agreement with "YouTube" consists of the terms and conditions found at the following link: https://www.youtube.com/static?gl=de&template=terms. These terms constitute a legally binding agreement between you and YouTube regarding your use of the Services. Google's privacy policy explains how YouTube handles and protects your personal data when you use the service.

f) Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience.  Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and to tailor our product range according to our users' feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. It is contractually forbidden for Hotjar to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

10. E-mail communication and newsletters for advertising purposes

If you subscribe to our newsletter, we will use your e-mail address to send you information about our services and other commercial communications (e.g. announcements of events, competitions, promotions and surveys) that may be of interest to you. For security reasons, we use the so-called double opt-in procedure to subscribe to the newsletter. If you subscribe to our newsletter, we will use your e-mail address to send you information about our services and other commercial communications (e.g. announcements of events, competitions, promotions and surveys) that may be of interest to you. You can unsubscribe from such newsletter emails at any time by clicking on the highlighted “Unsubscribe from this list” link at the bottom of each email or by contacting us directly by email at info@treesolution.com.

11. No automated decisions including profiling with legal effect

We will not make any decision about you that is based solely on automated processing—including profiling—and which produces legal effects concerning you or similarly significantly affects you.

12. Security

TreeSolution Security Awareness AG has implemented organizational and technical measures to maintain the security of personal data and to protect it against unauthorized or unlawful processing, accidental loss, alteration, disclosure or access.

TreeSolution Security Awareness AG may employs third parties as data processors to collect and process your personal data. The data processors commissioned by us will only process your personal data as instructed by us and be legally obliged to take strict security precautions when handling personal data.

Unfortunately, the transmission of information over the Internet is not entirely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data submitted to our website; any data submission is at your own risk. For this reason, you are free to submit your personal data to us at any time by other means, e.g. by telephone. Once we have received your data, we apply strict procedures and security measures to prevent unauthorized access.

13. Privacy policies of third-party providers

Please note that if you click on the link to a third-party website (e.g. Google or social media or other websites), you will be redirected to a website that we do not control and our Privacy Policy will no longer apply. Your browsing and interaction on any other website is subject to the terms of use, privacy policies and notices of those third party websites. Moreover, we cannot guarantee that these links are correct and up-to-date.

We recommend that you read the terms of use, the privacy policies and notices of other websites carefully before you submit personal data over this website. We will not be held responsible or liable for the information content and data processing of such third-party websites.

14. Children

We recommend that you read the terms of use, the privacy policies and notices of other websites carefully before you submit personal data over this website. We will not be held responsible or liable for the information content and data processing of such third-party websites.

15. What are your rights

By providing proof of your identity you can request information from TreeSolution Security Awareness AG about whether personal data about you is being processed. Additionally, you have the right to request the correction, deletion or restriction of your personal data and to object to their processing.  Provided that the processing is based on your consent or our legitimate interests, you can withdraw your consent or object to this processing at any time by contacting us directly at info@treesolution.com. In certain cases, you have the right to receive personal data generated during the use of online services in a structured, common and machine-readable format, so that it is possible for it to be further used and transmitted.

Inquiries related to this matter should be directed to TreeSolution Security Awareness AG to the following e-mail address: info@treesolution.com. TreeSolution Security Awareness AG reserves the right to restrict your rights within the framework of applicable law and, for example, not to disclose comprehensive information or delete personal data. Please note that even after a request to delete your personal data, we must retain all or part of it within the scope of the statutory and contractual retention obligations. The deletion of your personal data may result in you no longer being able to use our services.

If we reject your request or you are not satisfied with us processing your data, you also have the right to file a complaint with the competent supervisory authority and to seek remedy from the competent authority. The competent authority is the Federal Data Protection and Information Commissioner (Eidgenössische Datenschutz- und Informationsbeauftragte − EDÖB) in Bern, Switzerland (http://www.edoeb.admin.ch).

16. Changes to our Privacy Policy

TreeSolution Security Awareness AG reserves the right to amend, supplement or otherwise change this Privacy Policy at any time and without stating reasons. The current Privacy Policy as published on the portal applies.