Registered User Terms & Conditions

ANY PERSON OR ENTITY ("User"), REGISTERED TO USE OR ACCESS THE SITES AT pointblanklondon.com AND pointblankmusicschool.com (“Sites”) OR ANY INFORMATION CONTAINED WITHIN THE SITES, AGREES TO AND IS BOUND BY THE FOLLOWING TERMS AND CONDITIONS OF THIS REGISTERED USER AGREEMENT ("Agreement"):

1. CONTRACTING PARTIES

When you register with either Sites, you are contracting with pointblank Limited, of [new address?] . pointblank Limited is referred to in these terms and conditions as "we", "us", "our" or “pointblank”.

2. PASSWORDS

You agree: to keep your password secure and confidential and to not allow anyone else to use your email address or password to access the Sites; to not do anything which would assist anyone who is not a registered User to gain access to any secured area of the Sites, and; to not create additional registration accounts for the purpose of abusing the functionality of the Sites, or other users, or to seek to pass yourself off as another User. If you think someone else has obtained your account details, please let us know immediately and we will close your account as quickly as possible. You will be responsible to pointblank and to others for all activity that occurs under your registration account.

3. YOUR PERSONAL INFORMATION

You agree to provide only true, accurate and complete information to us and/or the Sites. Any personal information provided by Users will be treated with appropriate care and security in accordance with our Privacy Policy.

4. CONTENT

Your use of the Sites and/or all content contained within the Sites (“Content”) is entirely at your own risk. Please note, whilst we endeavour to provide accurate and up-to-date information, the Content may not be wholly accurate or up-to-date, complete or free of defects, and is subject to change, often at very short notice. All Content is provided without any representations or warranties of any kind (implied or express) to the fullest extent permitted by applicable law. pointblank, unless otherwise stated herein, owns or controls all relevant intellectual property rights in the Sites and the Content. You may not publish, distribute, extract, re-utilise, or reproduce any part of the Sites or Content in any form (including storing it in any medium) other than as expressly allowed herein or as permitted on the Sites or under UK or local law. The Sites and the Content are for your personal, non-commercial use only, and are not for re-distribution, transfer, assignment or sublicense.

5. OBJECTIONABLE MATERIAL

If you encounter or become aware of any objectionable or infringing or unlawful content posted anywhere on the Sites, please immediately report such material (and the specific page on which it is found) to pointblank. Please note that there may be adverse legal consequences if you make a false or bad faith allegation through this process.

6. SUBMITTING MATERIAL

If you upload any material to the Sites (including, without limitation, text, photographs and/or written comments) you hereby grant to us a worldwide, perpetual, non-exclusive licence to use that material in any media. You further agree to waive your moral rights for the purposes of this licence. You warrant and represent that you personally created, wrote and produced such content and all materials contained within such content. We reserve the right to cut, edit, crop or arrange your material as necessary in our discretion. Unless you have requested otherwise, your name may be published alongside your material. If you do not want to grant these rights, please do not submit material to the Sites.

7. CODE OF CONDUCT FOR USER CONTENT

You agree that you are responsible for everything that you post or transmit to the Sites and you agree (in relation to the Sites):

not to post content or participate in any form of activity via the Sites which is unlawful, harassing, libellous, defamatory, abusive, threatening, harmful, vulgar, obscene, profane, sexually-oriented, racially-offensive or otherwise includes objectionable material;

• not to post content which you do not have the right to use;
• not to abuse other Users;
• not to spam other Users or anyone else;
• not to publish your own contact details or those of anyone else;
• not to register more than one account for yourself or anyone else.

You acknowledge and accept that when you upload material to the Sites, you may be exposed to comments or critical submissions from other Users that are unfair, inaccurate, offensive, indecent, or otherwise objectionable to you and you hereby waive any rights or remedies you have or may have against us with respect to any such comments or submissions.

8. LIABILITY

You agree that the liability of pointblank to you hereunder shall be limited to the lesser of: (1) the amount you have actually paid to pointblank for its products or services; and (2) one hundred pounds (£100). Except as set out herein, pointblank shall not be liable for any indirect or consequential loss of any kind in contract, tort or otherwise arising out of your use of the Sites or in relation to the goods and/or services that we provide. Nothing in this Agreement shall operate to limit or exclude liability for death or personal injury caused by negligence of pointblank.

9. INDEMNITY

You agree to indemnify pointblank for any loss or damage that may be incurred by pointblank, including without limitation legal fees, arising from any breach by you of any warranty or other term herein or your misuse of any material or information obtained through the Sites. You further undertake to indemnify pointblank for all loss or damage incurred by pointblank in relation to any third party claim against pointblank for infringement of intellectual property rights arising in relation to your provision of materials to the Sites.

10. TRADEMARKS

The brands, products and service names used or appearing within the Sites (including, without limitation, “pointblank") are the trade marks or trade names of pointblank or its trading partners unless otherwise stated. You may not distribute products or offer services under or by reference to or otherwise use or reproduce any such trade marks, trade names or taglines without the prior written permission of pointblank.

11. HACKING

You agree and undertake not to attempt to damage, deny service to, hack, crack, reverse-engineer, or otherwise interfere (collectively, "Interfere") with the Sites in any manner. If you in any way Interfere with the Sites, you agree to pay all damages incurred by pointblank. pointblank will cooperate with the authorities in prosecuting any User who Interferes with the Sites or otherwise attempts to defraud pointblank or any other parties through your use of the Sites or services provided via the Sites. pointblank reserves the right to deny any or all access or service to any User for any reason, at any time, at our sole discretion. You agree that we may block your IP address or addresses at any time, and at our sole discretion to disallow your continued use of the Sites. We reserve the right to take any action we may deem appropriate in our sole discretion with respect to violations or enforcement of the terms of this Agreement, and we expressly reserve all rights and remedies available to us at law or in equity.

12. NO PARTNERSHIP

Your use of the Sites and/or the content creates no partnership, client, fiduciary or other professional relationship.

13. ENTIRE AGREEMENT

This Agreement constitutes the entire agreement between the parties on the subject matter hereof. There are no understandings, agreements, or representations, oral or written, not specified herein regarding this Agreement.

14. FORCE MAJEURE

We will not be liable or responsible for any failure to perform, or delay in performance of, any of our obligations under a Contract that is caused by events outside our reasonable control.

15. SEVERANCE

If any part, term, or provision of this Agreement shall be held by a court of competent jurisdiction to be illegal, unenforceable, or in conflict with any relevant law, the remaining portions or provisions shall still remain valid and continue in full force and effect.

16. NO WAIVER

No waiver, express or implied, by either party of any term or condition or of any breach by the other of any of the provisions of this Agreement shall operate as a waiver of any breach of the same or any other provision of this Agreement.

17. VARIATION

This Agreement may be varied from time to time by our posting new terms on the Sites, and any such amendment will be applicable to all Users from the date and time such revised terms have been posted on the Sites. Your continued use of the Sites or services constitutes agreement with and acceptance of any such amendment or other changes.

18. LAW AND JURISDICTION

This Agreement shall be governed by and will be construed in accordance with the laws of England and Wales. Any disputes arising under or in connection with this Agreement shall be subject to the exclusive jurisdiction of the English Courts.

19. CONTACTING US

For enquires regarding the Sites and returns, please contact us at the following address: pointblank Limited, 23-28 Penn St, London N1 5DL, or contact us at info@pointblanklondon.com.

Privacy Notice

1. POLICY STATEMENT

This Privacy Notice (“Notice”) sets out what personal information pointblank Music School (“pointblank”, “We”, “us”, “our”) collects and how that information is processed when you visit the websites located at www.pointblankmusicschool.com (“Sites”) and/or the services provided from the Sites (“Services”).

This Privacy Notice describes, in a clear and accessible way, how pointblank complies with data protection legislation. This includes the purposes and legal basis for each type of processing, any transfers or third party recipients of personal information, and the timescales for storing and processing them. This Policy also outlines your rights and obligations regarding data protection.  

This Privacy Notice applies to all applicants, students, alumni, subscribers and anyone else about whom pointblank may have reasons to collect and process data, including personal information, either online and/ or offline.

pointblank is committed to protecting and respecting your privacy. We only collect personal information necessary to provide the services that you requested, the use of your personal information will not be excessive and we take reasonable security measures to protect it. If we require your consent for any specific use of your personal information, we will collect it at the appropriate time and you can withdraw it at any time. We do not sell your personal data to third parties under any circumstances or use your personal information to carry out any wholly automated decision-making that affects you.

This Statement applies only to this website. For example, it does not apply to banners, advertisements or promotions we may sponsor or participate in on websites owned by third parties. Other websites linking to or from this website may have different policies and we are not responsible for the privacy practices of such other sites. You should read any other applicable privacy policies carefully before using other websites.

pointblank is registered as a data controller with the Information Commissioner’s Office (“ICO”) with registration number Z9800809.

2. WHAT IS ‘PERSONAL INFORMATION’?

‘Personal information’ refers to any information which relates to or identifies you as an individual (“Data subject”) of which the following are examples: names, photographs, addresses, phone numbers, emails, IP addresses, payment details, social media account ID, screen name/ nickname, passport details, browser and device information, server log file information and information collected through cookies.

3. YOUR RIGHTS AND OBLIGATIONS

You have the following rights (all of which are qualified in different ways) under Data Protection law:

• to be informed about how your personal information is being used
• to access the personal information we hold about you
• to request the correction of inaccurate personal information we hold about you
• to request we delete your personal information, or stop processing/ collecting it
• to withdraw consent to receiving marketing communications from us
• to request we transfer or port elements of your data either to you or another service provider
• to complain to your data protection regulator, which the UK is the ICO
• to request information about the reasoning behind any automated decision

It is also your responsibility to ensure the information about you that is held by pointblank is correct and up-to-date. Please keep us informed of any changes to your personal information by writing to us, or if you have an account with us, by logging into your account to edit your profile.

4. WHEN DO WE COLLECT INFORMATION FROM YOU

Information is crucial to ensuring we can understand, tailor, and deliver the best services to you. It helps us operate as efficiently as possible and to make sure our interactions with you are timely and relevant to you. To do this, we may collect information about you when you:

• visit our website
• subscribe to our newsletter
• access our free offerings
• participate in our competitions
• register for an event hosted by us
• attend an open day or school tour
• Enrol on/ register for a course
• enquire about a course
• engage with us on social media

5.1. HOW WE USE YOUR PERSONAL INFORMATION (PROSPECTIVE STUDENTS)

Higher Education (“HE”) programmes

pointblank will use the personal information you provide on your enrolment/ application form (either through UCAS or direct application), together with any supporting documents, additional details provided by referee and notes followed by any interview (if applicable), to form part of the admissions process. 

Professional courses

pointblank will use the personal details you provide on your application form for registration and course administration purposes.

What is the purpose and legal basis of the processing?

pointblank will process the personal information and additional information provided on your application for the purposes of identifying you, processing your application, verifying the information provided, deciding whether to offer you a place for the course you have applied for, and communicating that outcome together with any feedback.

We may also use or disclose the information provided for the following statutory or public interest purposes:

• To prevent or detect fraud
• For equal opportunities monitoring
• To help us to make reasonable adjustments for any disability, as requested by you
• To provide statutory returns required by applicable legislation
• For research and statistical purposes, but no information which could identify you will be published

We consider the processing of your personal information for the above purposes to be either necessary for us to take steps with a view to creating a contractual relationship with you (e.g. to assess your application to study with us), or necessary for compliance with a legal obligation (e.g. equal opportunities monitoring), or necessary for the performance of tasks we carry out in the public interest (e.g. admissions research). We require you to provide us with the information we ask for during the application process in order to assess your application properly except where its supply is marked as optional. Admissions decisions are not automated.

Who will my personal information be shared with?

As well as circulating your application and related materials to the appropriate staff at pointblank, we may share your personal information for the above purposes as relevant and necessary with:

• Your referees
• Where relevant and as required and/or notified to you, your school/college or training organisation
• Your examination boards or awarding bodies
• Your student support assessment body
• Your funders and/or potential funders (including, as relevant, the Student Loans Company)
• In the case of international applicants, the British Council or appropriate agencies
• Where relevant and as required, UK Visas and Immigration in order to act as your sponsor for visa purposes
• Where relevant and as required, governmental bodies including local authorities, the Home Office, HMRC and the Department for Work and Pensions and its agencies
• Other Higher Education organisations, in order to assist with tracking and research into access to Higher Education
• Companies or organisations providing specific services to, or on behalf of pointblank

How is my personal information used if I am accepted?

If you are accepted for an undergraduate degree, we will use your personal information for the purposes described in the following section ‘HE Students’.

5.2. HOW WE USE YOUR PERSONAL INFORMATION (HE STUDENTS)

pointblank will keep a record of the details you provided during the admission process and will also maintain records about your studies at pointblank, and your use of the facilities and services that we offer.

Your personal information is created, stored and transmitted securely in a variety of formats, including our student records databases. Access to your personal information is controlled and limited only to the relevant staff at pointblank or those who work on behalf of pointblank.

In addition to this, pointblank may process some information about you that is classed as ‘sensitive’ or ‘special category’ personal information, and which requires additional protections. This includes information concerning your ethnicity, sexual orientation, religious beliefs or health/ disability that we use for obligatory data returns, planning and monitoring purposes, or in order to provide care, help or suitable adjustments.  Access to, and the sharing of, your ‘sensitive’ personal information is controlled very carefully.

What is the purpose and legal basis of the processing?

pointblank will process your personal information for a range of contractual, statutory or public interest purposes, including the following:

• To deliver and administer your education, and record the details of your studies
• To determine/confirm your academic achievements (e.g. grades)
• To administer the financial aspects of your relationship with us and any funders
• To deliver facilities to you (e.g. IT, libraries, studio booking, VLE, video capture of lectures and masterclasses)
• To enable your participation at events (e.g. functions, graduation)
• To communicate effectively with you, including the distribution of relevant announcements and circulars
• To fulfil our legal obligations to return student data to the Higher Education Statistics Agency (Please refer to HESA’s data collection notice) and other relevant governing bodies as required
• To operate security (including CCTV), governance, disciplinaries (including plagiarism and academic misconduct), complaints, audit and quality assurance processes and arrangements
• To compile statistics and conduct research for internal and statutory reporting purposes
• To fulfil and monitor our responsibilities under equalities, immigration and public safety legislation
• To enable us to contact your next of kin in the event of an emergency (we will assume you have checked with the individuals before you supply their contact details to us)
• To promote and communicate careers and alumni events and newsletters with you

We consider the processing of your personal information for these purposes to be either necessary for the performance of our contractual obligations with you (e.g. to manage your student experience and welfare while studying at pointblank), or necessary for compliance with a legal obligation (e.g. equal opportunities monitoring), or necessary for the performance of tasks we carry out in the public interest (e.g. teaching), or necessary for the pursuit of the legitimate interests of pointblank or relevant external organisations.  

Who will my personal information be shared with?

As described above, your personal information is shared with relevant staff at pointblank as required. In addition, it is shared as permitted or required by law, on a considered and confidential basis, with a range of external organisations, including the following:

• Higher Education Statistics Agency (see HESA’s statement about the uses made by them of your personal information published at https://www.hesa.ac.uk/about/regulation/data-protection/notices)
• Your funders and/ or sponsors as relevant (e.g., the Student Loans Company)
• Partnership Institution/ Qualification Awarding bodies (e.g. Middlesex University)
• External examiners and assessors, and external individuals involved in relevant University committees or procedures
• Relevant Government Departments (e.g. Department for Education, Home Office, Foreign and Commonwealth Office, Department of Health)
• Relevant executive agencies or non-departmental public bodies (e.g. UK Visas and Immigration, HM Revenue and Customs, the Health and Safety Executive)
• Relevant Higher Education bodies (e.g. Higher Education Funding Council for England, Office for Students, UK Research and Innovation, Universities and Colleges Admissions Service, Office for Fair Access, Office of the Independent Adjudicator, the organisation(s) running the National Student Survey and other student and leaver surveys)
• Local authorities
• On occasion and where necessary, the police and other law enforcement agencies
• On occasion and where necessary, auditors
• Companies or organisations providing specific services to, or on behalf of, pointblank

Other than as set out above, we will not normally publish or disclose any personal information about you to other external individuals and/ or organisations unless you have requested it or consented to it, or unless it is in your vital interests to do so (e.g. in an emergency situation).

5.3. HOW WE USE YOUR PERSONAL INFORMATION (NON-HE STUDENTS)

pointblank will use the details you provided for registration and course administrative purposes. We may aggregate or anonymize such data (where necessary) for statistical and course improvement purposes upon the completion of the course.

What is the purpose and legal basis of the processing?

pointblank will process your personal information for a range of contractual, statutory or public interest purposes, including the following:

• To deliver and administer your education, and record the details of your studies
• To determine/confirm your professional achievements (e.g. certificate)
• To administer the financial aspects of your relationship with us
• To deliver facilities to you (e.g. use of studio or equipment)
• To enable your participation at events/ functions
• To communicate effectively with you on matters related to your course
• To operate security (including CCTV), governance, disciplinaries, complaints, audit and quality assurance processes and arrangements
• To compile statistics and conduct research for internal reporting purposes
• To fulfil and monitor our responsibilities under equalities, immigration and public safety legislation
• To enable us to contact your next of kin in the event of an emergency (we will assume you have checked with the individuals before you supply their contact details to us)

Who will my personal information be shared with?

As described above, your personal information is shared with relevant staff at pointblank as required. In addition, it is shared as permitted or required by law, on a considered and confidential basis, with a range of external organisations, including the following:

• Your funders and/or sponsors
• Relevant executive agencies or non-departmental public bodies (e.g. UK Visas and Immigration, HM Revenue and Customs, the Health and Safety Executive)
• Local authorities
• On occasion and where necessary, the police and other law enforcement agencies
• On occasion and where necessary, auditors
• Companies or organisations providing specific services to, or on behalf of, pointblank

Other than as set out above, we will not normally publish or disclose any personal information about you to other external individuals and/ or organisations unless you have requested it or consented to it, or unless it is in your vital interests to do so (e.g. in an emergency situation).

5.4. HOW WE USE YOUR PERSONAL INFORMATION (JOB APPLICANTS)

pointblank will use the details you provide on your application including CV and covering letter and any supporting documents requested following any interview process.

You may also be required to undergo certain additional recruitment checks or procedures as part of the job application and offer process (e.g. criminal convictions checks or visa application procedures).

What is the purpose and legal basis of the processing?

pointblank will process the personal information provided on your application and the other information referred to above for the purposes of:

• identifying you
• processing your application
• verifying the information provided and assessing your suitability for the role (including any relevant right to work checks)
• deciding whether to offer you a job, and communicating that outcome (together with any feedback)

We may also use or disclose the information provided for the following statutory or public interest purposes:

• To prevent or detect fraud.
• For equal opportunities monitoring.
• To help us to make reasonable adjustments for any disability, as requested by you.

We consider the processing of your personal information for the above purposes to be either necessary for us to take steps with a view to creating a contractual relationship with you (e.g. to assess your application for employment with us), or necessary for compliance with a legal obligation (e.g. equal opportunities monitoring). We require you to provide us with the information we ask for during the application process in order to assess your application properly except where its supply is marked as optional. Application decisions are not automated.

Who will my personal information be shared with?

As well as circulating your application and related materials to the appropriate staff at pointblank, we may share your personal information for the above purposes as relevant and necessary with:

• Where relevant and as required, the Disclosure and Barring Service or UK Visas and Immigration in order to administer relevant recruitment checks and procedures
• Your referees
• Companies or organisations providing specific recruitment services to, or on behalf of pointblank.

In all cases, we will only use any information gathered as part of any relevant check or procedure for that specific purpose, and we will handle, store, retain and destroy relevant materials in accordance with applicable legislation and codes of practice.

5.5. HOW WE USE YOUR PERSONAL INFORMATION (SUBSCRIBERS)

Please refer to ‘Registered User Terms and Conditions’ on our website for further information.

5.6. HOW WE USE YOUR PERSONAL INFORMATION (SITE VISITORS)

Please refer to our ‘Cookies policy’ in the following section and the ‘Site Visitors Agreement’ on our website.

6. COOKIES POLICY

A “cookie” is a small amount of data sent from the server and stored on your computer's hard drive. We use 'cookies' while you access the Sites to avoid the need to re-enter details on different occasions. Occasionally, we use session recording or click tracking software (e.g. Google Analytics) to understand how you interact with our websites, for example by scrolling the page, or clicking your mouse on a particular link.

The information is used for analysing sites activities and generating insights to allows us to improve your online experience. Examples include:

• enabling our service to recognise your device so that you don't have to give the same information several times during one task
• recognising that you may already have given a username and password so that you don't need to do it for every web page requested
• measuring how many people are using services, to make the services easier to use and to ensure sufficient capacity for quick delivery to your web browser
• adding new features or removing element that make the website difficult to use
• informing the choice of words and images that appear on the site to improve responses to our campaigns
• informing future changes to website design and functionality

Depending on the type of device you’re using and settings, it may supply us with additional information about the device type, your operating system, and details associated with this. Only your interaction with our website is captured and we receive no information about other sites you may view.

Most web browsers are automatically set up to accept cookies, but you can set your browser to refuse cookies or ask your browser to show you where a cookie has been set up. Please note that certain features of the Sites are only activated by the presence of a cookie and if you choose to refuse cookies these features may not be available to you. All modern browsers allow you to change your cookie settings. These settings will typically be found in the 'options' or 'preferences' menu of your browser. In order to understand these settings, the following may be helpful (otherwise you should use the 'Help' option in your browser for more details):

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari

Please note that we do not recommend turning cookies off when visiting pointblankmusicschool.com as this will prevent you from using many of the services on the Sites. For further information about cookies and how to control their use, please visit the following third party educational resources: www.allaboutcookies.org and www.youronlinechoices.eu.

Manage the preferences

7. WHAT IF I AM UNDER 18?

For the protection of children’s privacy, we require parental consent from users who are under the age of 16, who wish to enquire and/ or enrol our courses. If we become aware that a child under 16 has provided us with personal information, we will request a parental consent otherwise we will take steps to delete such information.

If you are over the age of 16 but under the age of 18, you should review the terms of this Privacy Policy with your parent or guardian to make sure you both understand them.

In certain circumstances, staff members at pointblank may have a duty to disclose sensitive information about students under the age of 18, or vulnerable adults, to designated colleagues or appropriate government agencies under the terms of our Safeguarding Policy or the Prevent Duty.

8. INTERNATIONAL TRANSFER

pointblank uses external providers to process, store and back-up our data. We also use cloud data storage. By default, data is stored at data centres located in the UK or the EU but in exceptional circumstances data may be processed at data centre outside UK/ EU. Your personal information will only be transferred to countries whose data protection laws have been assessed as adequate by the European Commission, or where adequate safeguards, such as the EU-US Privacy Shield, are in place to protect your personal information.

9. HOW LONG IS MY INFORMATION KEPT?

We will only keep your personal information for as long as it is necessary. For more details please refer to our Records Management and Retention Policy below:

Records Management & Retention Schedule

10. HOW CAN I ACCESS MY INFORMATION

You have the right, subject to certain exemptions, to access a copy of your personal information that is held by pointblank by submitting a request (commonly known as a ‘subject access request’).

If you wish to make a subject access request, please email dataprotection(at)pointblankmusicschool.com to request a form.

On receipt of your completed form, payment of fee (if applicable), verification of your identity, and sufficient details to enable us to locate the information, pointblank is obliged to respond within one calendar month. In circumstances where the request is excessive, we may extend the deadline for up to two months to provide a full response. If so, we will notify you of this extension and the reason it has been applied.

The information will be supplied subject to any applicable exemptions. The data will be provided as of the date of receipt of your request.

11. HOW TO CHANGE THE WAY WE CONTACT YOU

You have the right to stop receiving marketing communications from us if you wish, you can do so at any time by one of the following methods:

• Click ‘unsubscribe’ in any of the previous emails we sent you
• Log into your pointblank account and untick the box for Newsletter under My Home> Edit Profile

It might take up to 14 days for our system to be updated, so you might still receive messages from us while we process your request. Please be aware that stopping marketing communications will not stop student service communications (such as student updates/ notification), which are essential communications if you are studying at pointblank.

12. CHANGES TO THIS POLICY

This information was last updated in December 2020. It will be reviewed periodically and updated at least annually. The amended information will apply from the date it is posted and will govern the way in which we collect and use personal information from then on.

CONTACT US

If you have any queries about this Privacy Notice or would like to exercise your rights, please contact us at dataprotection(at)pointblankmusicschool.com.

The data controller of personal information collected through this website is: pointblank Ltd, registered company number 2963163.

The Sites, together with all content are owned or controlled by pointblank Limited, with its registered office at 23-28 Penn St, London N1 5DL. By visiting the Sites, you are accepting and consenting to the practices described in this Privacy Policy.