Privacy policy
1. Introduction
Libro.fm is committed to respecting the privacy rights and concerns of all users of our Service. The Libro.fm Service includes (a) any internet sites operated by Libro.fm, including without limitation the Libro.fm website at https://libro.fm/, the Libro.fm Blog (https://blog.libro.fm/), and Bookstore Link (https://www.bookstorelink.com/) (collectively the “Site”); (b) software made available through or in connection with the Libro.fm Service including mobile applications or apps (the “Service Applications”); and (c) the sale of audiobooks, memberships, credit bundles, clothing and other merchandise (collectively the “Products”) through the Site and the Service Applications. Together, the Site, Service Applications and the sale of Products are collectively referred to as the “Service.” Libro.fm has established and implemented this Privacy Policy to help you make informed decisions when using the Libro.fm Service.
The Libro.fm Terms of Use and this Privacy Policy describe the terms and conditions applicable to your access and use of the Service.
Please note that different privacy terms may apply to you based on where you live. Make sure you read the jurisdiction specific privacy terms for your country of residence located at the bottom of this Privacy Policy. There are currently jurisdiction specific privacy terms for users in Canada, the United Kingdom, Australia, and New Zealand as set out in Sections 12, 13, 14, and 15. The jurisdiction specific section might include additional information required under your local data protection laws, and may render certain aspects of the general Privacy Policy to be inapplicable, or amend them accordingly to ensure compliance with your local data protection and privacy laws. As such, please be sure you review this Privacy Policy in its entirety.
By using or interacting with the Service, you are entering into a binding contract with Libro.fm and acknowledge the use of your information as explained in this Privacy Policy. If you don’t agree with these terms, then please don’t use the Service.
2. Information we collect
This Privacy Policy relates to “personal data”, “personal information” or “data”, which are terms used by privacy and personal data regulators used around the world to cover the same type of data or information: that is, data or information that is information about you as an identifiable individual or that can be linked to you as an identifiable individual.
Information We Collect Directly From You. The type of information that we collect from you depends on your interaction with our Site and Services.
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You must create an account to purchase audiobooks or memberships from the Site. To create an account, you must provide your name, email address, country, postal code or zip code, and password. You can also choose to support a specific bookstore. We also may collect additional optional information from you such as how you heard about us and other contact information.
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If you become a member or make a purchase, you must provide your payment information, country, and zip code or postal code to our payment processor. For a purchase requiring shipment, we will collect your shipping address.
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We will also collect information about your purchases, returns, gifts and recipients, statistics about your accomplishments as a listener and bookstore supporter, preferences such as language and genre and your email and club type when you sign up for book clubs.
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If you refer a friend, we will collect the contact information you provide and may provide you with referral credits.
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Through its Audiobook Listening Copy (“ALC”) program, Libro.fm provides promotional copies of audiobooks to influencers, press, educators, librarians, and owners and employees of bookstore partners. If you apply for, or participate in, one of these ALC programs, we will collect your name and contact information and information to determine your qualification for the ALC program, including associated organizations, and social media channels for influencers. If you participate in one of the ALC programs, you agree that Libro.fm may share your name, organization, email address, social media and internet profiles, and ALC download activity with publishers and others as part of our ALC Program. The publisher’s use of your personal information is governed by their privacy policy.
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Libro.fm provides audiobooks to corporations and other organizations for distribution to employees and other recipients chosen by the organization. If you receive an audiobook from an organization, we may provide your name, email address and which book(s) you received to the organization in accordance with our agreement with the organization. The organization’s use of your personal information is governed by their privacy policy.
Information We Collect Automatically. We automatically collect the following information about your use of our Site or Services and your device through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; device information; web pages you view on our Site; links you click on our Site; your IP address; the length of time you visit our Site and or use our Services; and the referring URL or the webpage that led you to our Site. We will collect information about your purchases, quizzes, recommendations, preferences, playlists, and other activities on the Site and Services.
Cookies and Other Technologies
Like many websites, we employ "cookies" on the Site and Service to allow us to provide and improve your experience. Cookies are small bits of electronic information that a website sends to a visitor's browser. Each user is assigned a “cookie ID” from our Site domain in connection with the registration process. We use cookies, including your cookie ID, to store a user's log-in identity when you re-access the Site; to monitor irregular account behavior and to prevent fraud; and to generate and compile aggregated statistics that allow us to understand how users navigate our Site and Service. You may refuse the use of certain cookies by selecting the appropriate settings on your browser or device; however, if you do this, you may not be able to use the full functionality of the Site and Service.
Log Information
We also keep track of your interaction with the Site, Service and any other users. Specifically, our servers automatically record information that your browser (or our Service) sends whenever you interact with the Service. This information includes your Internet Protocol address (IP address), your cookie ID, your browser type and version, mobile operating system, mobile device type, app version, which aspects of Service you use and when and how long you use them, and how you otherwise access the Libro.fm Service.
Do-Not-Track
Currently, our Site and Services do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Third-Party Analytics
Our Site and Services may use services operated by third parties, such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Sites and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and you can opt out of them by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Social Plugins
We use Instagram, Facebook, X (formerly Twitter), TikTok, YouTube, and Vimeo social plugins on our Site. When you view a web page that contains a plugin, your browser will create a direct link to the third parties’ servers. If you are logged into your social media account, the social media platform will record the visit to your social media account. Please visit the social media platform’s privacy policy for more information.
Third-Party Ad Networks
We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you.
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (DAA) Consumer Choice Page for information about opting out of interest-based advertising and your choices.
Opting out from one or more companies listed on the DAA Consumer Choice Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA site, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info.
3. How we use your information
We may use the information we collect, including your personal information, to:
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provide, personalize, and improve your experience with the Site, Services and Products, for example by providing customized or localized content such as bookstore finder, recommended books, event notices, or advertising;
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ensure technical functioning of the Site and Service;
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provide customer support, including facilitating returns and refunds;
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develop new products, services and recommendations, and analyze your use of the Site, Services, and Products including your interaction with applications, advertising, Products and Services;
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communicate with you, including promotional emails or messages;
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enable and promote the Site and Services, including features, playlists, wish lists and content, such as sharing, user interactions, notifications and suggestions, and integration with third party services;
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allow you to participate in events, contests, sweepstakes, promotions, giveaways, look up bookstores and other similar activities;
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enforce this Privacy Policy and the Libro.fm Terms of Use, including to protect the rights, property or safety of us, users or any other person and the copyright-protected content; and
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as otherwise stated in this Privacy Policy or through our notice to you.
4. Your choices
To modify your email marketing preferences, please go to https://libro.fm/user and select “Edit account info” or or opt out using the unsubscribe link in the email. Even if you opt out of marketing emails, we may still email you regarding your transactions. Through your device and browser settings, you can change your cookie and advertising choices. When you login, you can edit your account information, choose to delete your account, manage your public wish list information, and change your bookstore.
5. Sharing of information with third parties
We may share your information in the following ways:
With Service Providers and Affiliates
We use third parties to manage portions of the Service, facilitate our business (e.g., by hosting our servers or providing payment processing services to us), manage communications with you, or otherwise provide services to us in connection with the Service. Your personal information may be transmitted to and from, and maintained and processed, by our affiliates and other third parties who provide services on our behalf in the U.S. or other jurisdictions.
With Bookstore Partners and Other Third Parties
As part of the Service, we allow you to support bookstore partners by designating a bookstore partner to receive a share of the profits from your purchases of audiobooks and memberships. When you have selected a bookstore partner, Libro.fm will share with that bookstore partner your name, email address, and purchases of audiobooks and memberships. As stated above, we also share information with publishers, authors, employers and others through our ALC and employee programs.
You can refer friends and create wish lists and share these with your friends and family.
When you receive an audiobook or membership as a gift or from an organization, we may provide confirmation that you received the audiobook or membership to the person or organization that gave it to you, along with identifying information about you.
We may also share your information with advertising networks, advertisers and analytics providers for the purposes of interest-based advertising.
We will share personal information we collect from you if we believe it is reasonably necessary to make the Libro.fm Service available to you, legally required, or otherwise permitted by you.
In addition to the above, we may also share your information with third parties: to allow a merger, acquisition, or sale of all or a portion of our assets; to respond to legal process; to inform business partners about use of the Libro.fm Service and products and services made available through the Libro.fm Service, in the form of aggregated statistics or otherwise in a format which does not reveal your identity; and if you expressly opt in to such sharing or when we otherwise notify you.
6. Additional information about third parties
This Privacy Policy does not cover the information practices of third party websites linked to the Site or Service, such as social networks and advertising networks. We are not responsible for their collection and use of your personal information. You should refer to the privacy policies and statements of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies.
7. Security
We are committed to protecting our users’ information. Your password protects your user account, so you should use a unique and strong password, limit access to your computer and browser, and sign off after having used the Service. While we take reasonable data protection precautions, no security measures are completely secure, and we do not guarantee the security of user information at any time.
8. Children's privacy
The Libro.fm Service is intended for users age 18 or older.
Through our kids’ book club and other marketing, we offer recommendations for children’s books for the use of parents and guardians only. We do not knowingly collect or maintain any personal information from anyone under the age of 13 nor is any part of our Site or Service directed to children under the age of 13. We will remove and/or delete any personal information we believe was submitted by any child under the age of 13.
9. Special note to users outside of the United States
The Site and Service is hosted in the United States. If you are a user accessing the Site or Service from the European Union, the United Kingdom, Australia, New Zealand, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from United States laws, please be advised that through your continued use of the Libro.fm Service, which is governed by U.S. law, this Privacy Policy, our Terms and our payment terms, you are transferring your personal information to the United States and you hereby acknowledge that the recipients of the information may not be required to protect the information in a way that, overall, provides comparable safeguards to those in your local data protection law, and you hereby consent to the transfer of such information outside of the country where you are located. For the avoidance of doubt, any information we or you may share with any social network may be transmitted to and stored by such parties on servers in the United States.
10. Changes and updates to Privacy Policy
This Privacy Policy may be revised periodically and this will be reflected by the date above. Please revisit this page to stay aware of any changes. In general, we only use your personal information in the manner described in the Privacy Policy in effect when we received the personal information you provided. Your continued use of the Libro.fm Service constitutes your agreement to this Privacy Policy and any future revisions.
11. Contact us
If you have any questions or comments about this Privacy Policy, please contact us at support@libro.fm or you may contact us by mail at: PO Box 70525, Seattle, WA 98127, USA.
12. Jurisdiction Specific Supplementary Privacy Terms - Canada
The following additional provisions apply only to individuals who reside in Canada.
CASL Policy.
We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”). Any electronic communication we send to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message (a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.
In addition to adopting and updating this CASL Policy, we undertake various transparency initiatives to ensure we comply with CASL, which include:
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Consent— we do not send you CEMs without your consent. This consent typically must be “express” (expressly acknowledged by you), but in certain circumstances can be “implied” or specifically exempt from consent requirements. We modified or adopted our sign-up, registration and consent forms in order to ensure that your consent is meaningful (i.e. informed and freely given) as per CASL. When we collect your electronic contact personal information, you will know the exact purposes behind the collection.
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Content— we adopted processes to ensure that our CEMs contain the following requirements prescribed under CASL, which will usually be in the footer of the CEM. We will:
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Identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;
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Provide you with our contact personal information; and
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Set out a clear, working unsubscribe mechanism or preference centre that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).
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Clarity— we ensured that each aspect of a CEM, including its header, content, or any links or URLs in the CEM) conveys the appropriate personal information, whether viewed individually or taken as a whole, so that you always know what you are clicking on.
If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days. If you have any questions or concerns about our unsubscribe options, you may contact us at the address indicated in Section 11 of the Privacy Policy above.
13. Jurisdiction Specific Supplementary Privacy Terms - United Kingdom
The following additional provisions apply only to individuals who reside in the United Kingdom.
For the purposes of a UK data subject, Libro.fm is the data controller of your personal data collected from you on the website or otherwise for the purpose of providing the Service to you. We can be contacted as provided in Section 11 of this Privacy Policy.
Why and on What Legal Basis we Use Personal Data.
All processing and use of your personal data is justified. The following is an overview of the legal grounds for processing personal data, and why we use your personal data:
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The processing is necessary in order to fulfill our commitments to you under our Terms of Use or other agreements with you or is necessary to administer your account – for example, in order to enable access to our Services on your device or to charge you for use of the Services;
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The processing is necessary for us to comply with a relevant legal or regulatory obligation – for example to keep accounting records and evidence of on-line sales;
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We have a legitimate interest in using your information – for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our services, and to evaluate transactions involving the website or our products and services. In these cases we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to such processing as explained in the section titled “Your Privacy Rights” below; or
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You have consented to the processing (e.g., to provide you with direct communication and marketing).
Data Transfers.
We operate on a global basis. Accordingly, your personal data may be transferred and stored in countries outside the UK and EU, including in the US, that are subject to different standards of data protection. We will take appropriate steps ensure that transfers of personal data are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
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we ensure transfers within our group will be covered by an agreement entered into by our members (an intra-group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within our group;
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where we transfer your personal information to third parties who help provide the Service, we rely on authorised transfer mechanisms and where necessary, we obtain contractual commitments from them to protect your personal information; or
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where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed.
You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.
Your Privacy Rights. You have the following rights in relation to any personal data which you provide to us in connection with accessing the Service:
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The right to withdraw consent – you can modify your marketing preferences using the opt-out link included in our email
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Right of access, rectification and erasure - you have the right to request access to and obtain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances.
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The right to prevent us from processing your data;
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The right to request copies of your data from us in a commonly-used and machine-readable format, for the purposes of transfer to a third party, where technically feasible; and
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The right to restrict our processing - you have the right to restrict our processing of your personal data where:
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you contest the accuracy of the personal data, until we have taken sufficient steps to correct or verify its accuracy;
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where the processing is unlawful but you do not want us to erase the personal data;
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where we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise or defense of legal claims; or
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where you have objected to processing justified on legitimate interest grounds, pending verification as to whether we have compelling legitimate grounds to continue processing.
Data Retention/Erasure. We will retain your personal information for as long as needed to provide the applicable Services and thereafter as permissible under applicable law. If, at any time after agreeing to this Policy, you: (1) change your mind about receiving information from us; (2) wish to revoke permission for us to retain and use your personal data; (3) wish to object to the processing of your personal information; or (4) wish for us to erase a copy of your data, please make a request to us at support@libro.fm. If you request erasure of your data, we may retain some of your personal information only for legitimate business interests, such as enhancing the safety of our Services; and to comply with our legal obligations, specifically our tax, legal reporting, and auditing obligations.
Complaints. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at any time if you have concerns about how we are processing your personal data. However, we ask that you please attempt to resolve any issues with us before referring the matter to the ICO.
Contact us. Please contact us at the address indicated in Section 11 of the Privacy Policy above if you wish to exercise any of your rights, or if you have any enquiries or complaints regarding the processing of your personal data.
14. Jurisdiction Specific Supplementary Privacy Terms - Australia
This Section 14 applies only to individuals who reside in Australia and explains how Company collects, uses holds, and discloses your personal information in accordance with Australian laws, in particular the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), to the extent that those laws require a different treatment to that set out in the Privacy Policy.
Collection and use
We collect, hold and use your personal information (which may include your identity, purchase history, use of the Service, and other details from your interactions with us) so that we can provide you with services, and manage our relationship with you. Please refer to sections 2 and 3 of the Privacy Policy for more information on how we collect and use your personal information.
If you do not provide us with your personal information we may not be able to provide you with our services, communicate with you or respond to your enquiries.
Storage and Security
In accordance with our obligations under Australian laws, we implement and maintain processes and security measures to protect personal information we hold from misuse, interference or loss, and from unauthorized access, modification or disclosure.
We also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any other purpose for which we are legally permitted to use that information.
Children
The Libro.fm Service is intended for users age 18 or older.
Through our kids’ book club and other marketing, we offer recommendations for children’s books for the use of parents and guardians only. We do not knowingly collect or maintain any personal information from anyone under the age of 16 nor is any part of our Site or Service directed to children under the age of 16. We will remove and/or delete any personal information we believe was submitted by any child under the age of 16.
Overseas disclosure
As indicated in section 9 of the Privacy Policy, we may disclose your personal information to recipients located outside Australia, specifically recipients located in the United States.
Access and Correction
You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out in Section 11 above. While we do our best to accommodate your requests, there are some circumstances in which we are not required to do so.
There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in providing you with that access. We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date and complete.
Complaints
If you have a complaint about the way in which we have handled a privacy issue, you should contact us using the details set out in Section 11 above. We will consider your complaint, determine what further actions are required, and notify you of the outcome of any investigation. If you are unhappy with how we have handled a privacy issue, you can contact the Office of the Australian Information Commissioner (www.oaic.gov.au).
15. Jurisdiction Specific Supplementary Privacy Terms - New Zealand
This Section 15 applies only to the extent Libro.fm is carrying on business in New Zealand and explains how Libro.fm collects, uses, stores, and discloses your personal information in accordance with New Zealand laws, in particular the Privacy Act 2020 (Privacy Act) and the Information Privacy Principles (IPPs), to the extent that those laws require a different treatment to that set out in the Privacy Policy.
Collection and use
We collect your personal information (which may include your identity, purchase history, use of the Service, and other details from your interactions with us) so that we can provide you with services, and manage our relationship with you. Please refer to sections 2 and 3 of the Privacy Policy for more information on how we collect and use your personal information.
If you do not provide us with your personal information we may not be able to provide you with our services, communicate with you or respond to your enquiries.
Access and Correction
You have the right to request access to or correction of the personal information that we hold about you. Where you wish to make a request, you can use our contact details set out in Section 11 above.
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