TRUSTe

MiTek Industries, Inc.
Privacy Policy

Last Updated on 2016-09-30

MiTek Industries, Inc. and MiTek USA, Inc. (“MiTek”) respect your privacy and are committed to safeguarding and protecting your privacy in connection with the collection of personal information. MiTek may collect your personal information for a variety of reasons. This Privacy Policy contains important information regarding MiTek’s privacy practices and the choices it offers individuals with respect to their personal information. If you choose to provide us with personal information, you are telling us that you have read, fully understand, and accept the privacy practices summarized in this Privacy Policy and consent to all actions that are consistent with and described in this Privacy Policy. We encourage you to read this Privacy Policy in its entirety to understand MiTek’s privacy practices before submitting any personal information to MiTek.

Summary

Scope of this Privacy Policy

This Privacy Policy applies to our collection and use of the personal information that we may obtain in a variety of ways, including through your use of www.mii.com; www.mitek-us.com; www.mitek.co.uk; www.mitek.cz; www.mitek.de; www.mitek.fi; www.mitek.fr; www.mitek.pl; www.posi-palkki.fi; www.mitek.hu; and www.mitekbaltic.lv (collectively, the “Sites” and each a “Site”) and our mobile applications. This personal information may take many forms, including: your name, home or other physical address, email address, telephone number, fax number, organization name, and/or job title. A fuller description of this Privacy Policy’s scope can be found here.

Information Collection

We collect personal information from you. This information may include:

  • information about you that you provide us, for example, by filing out a form on one of our Sites, by contacting us, or by providing us information about you in order to complete a transaction; and
  • Information we collect by automated means when you visit our Site, use our services, or view our online advertisements.

Please click here for further information about what we collect.

Our Sites may contain links to websites operated by others whose privacy practices are different from MiTek’s. This Privacy Policy does not apply to any information collected from you through such links or that you may provide on the websites you reach by utilizing those links. MiTek is not responsible for the content or privacy practices of websites linked to the Sites or any other MiTek-sponsored websites that are not designed and developed by MiTek. You are encouraged to use common sense when using our Sites and review the privacy practices of each website you elect to visit before submitting your personal information.

Information Use

We do not exchange, lease, or sell the personal information about you that you provide to us, or which we collect automatically, when you visit our Sites unless we have asked for and obtained your explicit (opt-in) consent. We may use this personal information for our internal business purposes, and to comply with our legal obligations, as further described here.

Data Security

We are concerned with the security of your personal information and consider the protection of personal information we receive from you as critical to our mission of delivering unrivaled software, products, and services to our customers. We deploy a combination of reasonable and appropriate physical, technical, and administrative safeguards to protect against the loss, misuse, unauthorized access, disclosure, tampering, alteration, and unauthorized destruction of any Personal Information. We follow generally accepted security standards in our operations to protect the security of your personal information, both internally and from outsiders, and to ensure the integrity of the personal information we process, taking into account the relative risks involved and the nature of the personal information in question. Unfortunately, with any transmission over the Internet, there is always some element of risk involved in submitting personal information. Further information on our security procedures and your responsibility for security can be found here.

Data Access, Integrity, & Choice

To the extent we collect or use any of your personal information, we want that information to be reliable, accurate, complete, timely, and relevant to its intended use. To accomplish this goal, we provide individuals with reasonable means of access and the ability to request data corrections or deletions.

You have choices about how we use your information, whether we communicate with you and, if we do communicate with you, what form that communication takes. We will use your personal information only for our internal business and legal purposes. Except in a limited set of exceptional circumstances provided for under the law, we will stop any further internal business use of your personal information if you write us and tell us that you no longer consent to such use (opt-out).

For more information regarding your options with respect to access, integrity, and choice, please click here.

Effective Date and Updates

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

If you have questions, concerns or requests regarding MiTek’s Privacy Policy, or MiTek’s collection or use of your personal information, please contact us immediately at:

MiTek USA, Inc.
Attn: Privacy Manager
16023 Swingley Ridge Road
Chesterfield, MO 63017
USA

Further, if you have an unresolved privacy or personal information use concern that we have not addressed satisfactorily, please contact our U. S. -based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

MiTek Privacy Policy

Scope of this Privacy Policy

This Privacy Policy applies to our collection and use of the personal information that we may obtain in a variety of ways, including through your use of www.mii.com; www.mitek-us.com; www.mitek.co.uk; www.mitek.cz; www.mitek.de; www.mitek.fi; www.mitek.fr; www.mitek.pl; www.posi-palkki.fi; www.mitek.hu; and www.mitekbaltic.lv (collectively, the “Sites” and each a “Site”) and our mobile applications.

When we use the term “personal information” in this Privacy Policy, we mean information that identifies, or can be used by us or on our behalf to identify, an individual. This may take the form of anidentification number, name, title, office/work location, e-mail address, payment information, telephone number(s), photo, department, reporting hierarchy, or home address. Personal Information does not include “Usage Data,” which we define as encoded information, aggregate information, anonymized information, or information that is publicly available and not combined with non-public personal information.

This Policy applies to information:

  • You provide to us voluntarily; and
  • We collect about you, as further described in this Privacy Policy.

We also have a Privacy Shield and Swiss Safe Harbor Privacy Policy that applies to personal information of persons residing in the European Economic Area (“EEA”) and Switzerland. It can be foundhere.If this Privacy Shield and Swiss Safe Harbor Privacy Policy applies to your personal information, then, with respect to that personal information, the terms of the Privacy Shield and Swiss Safe Harbor Privacy Policy control over any conflicting term in this Privacy Policy.

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INFORMATION WE COLLECT

Personal Information You Voluntarily Provide. If you voluntarily provide us with personal information, for example your name, email address, or phone or mobile number, we collect this personal information about you. You may voluntarily provide this information to us in a variety of way, including by filling out an online form, providing us with personal information in order to initiate or complete a transaction, or by contacting us with questions about the Sites or our products and services.

Personal Information We May Automatically Collect. When you download and use our services, we automatically collect information on the type of device you use, operating system version, and the device identifier. We use cookies and other technologies to collect information about you when you visit our Sites. This information may include:

  • Your browser type and operating system;
  • Web pages you view;
  • Links you click;
  • Your IP address;
  • Site you visited before coming to our site; or
  • Device Identifier.

Passive Information. We use this data for system administration, assess the traffic to our Sites, maintain and improve the Sites, and to analyze trends in the aggregate and administer the Sites.

Tracking Technologies. MiTek and its Agents may use cookies or similar technologies to improve users’ experience on our Sites, for example to personalize features of the Sites for you, to analyze the traffic, such as total visitors to pages viewed on the Sites, and to make improvements based on the data we collect, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Sites or service. To manage Flash cookies, please click here.

We partner with a third party to display advertising on our Sites or to manage our advertising on other websites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here [or if located in the European Union click here]. Please note you will continue to receive generic ads.

We use mobile analytics software to allow us to better understand the functionality of our mobile applications on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.

Please be advised that if you disclose Personal Information or Sensitive Personal Information through public message boards provided by MiTek, this information may be collected and used by others. We do not monitor these public message boards and take no responsibility for the security or confidentiality of any information posted on such boards.

We do not ask for, access, or track any location-based information from your mobile device at any time while you are downloading or using our mobile apps or services.

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USE AND TRANSFER OF INFORMATION

Our Use of Your Personal Information for Internal Business Purposes. We may use your personal information for our internal business purposes. Such internal business purposes could include, for example, using the information to complete a transaction with you. We may also use this information to contact you for various other business reasons, such as to:

  • Market our products and services to you;
  • Set up your user account;
  • Contact you on behalf of our affiliated companies or external business partners about a particular offering that may be of interest to you;
  • Ask you about your experience with our company, the Site, or our products and services;
  • Protect against or identify possible fraudulent transactions;
  • Determine the effectiveness of our advertising;
  • Allowing you to register for MiTek University; and
  • Enforce our Terms and Conditions and otherwise manage our business.

We may also provide your personal information to our affiliated companies and to third parties whom we have retained to assist us with our internal business purposes such as an email service provider, platform hosting provider, payment processor, vendors and service providers. Prior to transferring your personal information to such affiliated companies or third parties, we will obtain their reasonable assurances that they will treat your personal information in accordance with the terms of this Privacy Policy.

Our Use of Your Personal Information for Legal Purposes. While MiTek will only provide such personal information that we in good faith believe is required to comply with the law, order, or other legal process, we may disclose certain personal information to comply with the law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

We may also disclose certain information:

  • If we are required to bring, or defend against, litigation, or any regulatory proceeding between, or relating to, you and us, and
  • We have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may have breached the Terms of Use of one of our Sites or who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Sites users, or anyone else who could be harmed by such activities.

Information Transfer. Your personal information may be transferred to, stored, and processed in a country other than the one in which it was provided. This may include the United States. When we do so, we transfer the information in compliance with applicable data protection laws.

We take steps to protect personal information no matter what country it is stored in or transferred to. We have procedures and controls in place, as appropriate, to help ensure this.

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Posting an Ad

When you post an ad on our site for machinery that you wish to sell, we may ask you for contact information (such as name and email address), description of the machinery, price or price range, and electronic photo for sale items. You may send as many as you like, but we are limited to posting two (preferably one) per machine or line. Your personal information will not be shared with other users, but will be used in order for you to be contacted through the site regarding your Ad.

DATA SECURITY

We take appropriate steps that we believe are reasonable to protect the security of your personal information on our system, both internally and from outsiders, and to ensure the integrity of the personal information we collect. We use a combination of technological, physical, and policy methods to protect this personal information, such as, for example, requiring a password to access our network, employing firewall and system log security, and providing employee policies and training regarding appropriate use of personal information.

You are responsible for maintaining the secrecy of your passwords and any account information. Please be aware that we will never ask you for your password in an unsolicited phone call or e-mail.

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ACCESS, INTEGRITY & CHOICE

Access & Integrity. If you reasonably believe that we hold personal information about you that is, in context, inaccurate, incomplete, untimely, or not relevant to its intended use, you maycontact us and request that we correct, update, or delete this information. We will take reasonable steps, as appropriate to the context, to correct inaccurate or incomplete information, or to delete untimely or irrelevant information, upon reasonable demonstration that the information is inaccurate, incomplete, untimely, or not relevant to its intended use. In connection with such requests, we reserve the right to: (1) request and obtain reasonable information from you confirming your identity; (2) request and obtain information from you necessary to correct or update the information; (3) reject and/or ignore requests if we determine that such requests are repetitively made, or otherwise lack a good faith basis; and (4) take no further action with respect to your request if you fail to reasonably provide the information described in (1) or (2). We will timely respond to your request.

If you wish to remove your photo from your profile, please delete it by logging into your account or by contacting us at the link provided above.

Choice. When you provide personal information to us, you consent to our using that information for our internal business and legal purposes as described in this Privacy Policy. If you do not want us to continue using your personal information for our internal business purposes, you may request that we stop doing so (opt-out) by contacting us. We will honor your opt-out request except in very limited circumstances. We may not honor your request if there is a compelling need to further use your personal information, for example, if we are compelled by law to provide your personal information, or we require the use of your personal information for purposes of litigation or investigation, or for other legal purposes. We may also need to keep the information we have collected about you for internal use only, such as for statistical analytics and compliance reasons, to the extent permitted by law.

We also give you choices about how we communicate with you.

  • Digital / Electronic Communications(examples: email, mobile). We only send you promotional mobile or email messages if you explicitly ask to receive these. (Opt-in). You can stop receiving promotional mobile and email messages from us by following the instructions provided in any such message you receive.
  • Postal Mail. Where permitted by law, we may mail you unsolicited offers or product information that we believe is of interest to you. You can stop receiving promotional postal mail from us. Promotional postal mail may contain opt out instructions, and you can also stop receiving promotional postal mail by following those instructions.

You can also stop receiving promotional email or postal communication from us by contacting ourPrivacy Manager. Please place the word “UNSUBSCRIBE” in the “Regarding” line of your letter, and provide your contact details to enable the Privacy Manager to identify you and complete your request.

PLEASE NOTE: If you choose to stop receiving promotional messages from us, we will honor your request. However, we will continue to send you service related communications.

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MiTek Industries, Inc. and MiTek USA, Inc. (“MiTek”) respect and protect individual privacy. This Privacy Shield and Swiss Safe Harbor Privacy Policy (“Policy”) describes the principles MiTek follows with respect to the transfer of Personal Information from the European Economic Area (“EEA”) (which includes the twenty-seven Member States of the European Union (“EU”) plus Iceland, Liechtenstein, and Norway), and from Switzerland, to the United States.

The United States Department of Commerce and the European Commission have established a program (the “Privacy Shield”) that entails certain agreed-upon privacy protection principles (“Privacy Shield Principles”) to enable U. S. companies to satisfy EU law requirements for adequate protection of Personal Information transferred from the EU to the United States. The United States Department of Commerce and the Federal Data Protection and Information Commissioner (“FDPIC”) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U. S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “Swiss Safe Harbor Framework”). MiTek is committed to adhering to these Privacy Shield and Swiss Safe Harbor Principles.

MiTek participates in the Privacy Shield and has certified that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability. MiTek’s practices with respect to each of these Privacy Shield Principles are detailed below. If there is a conflict between the privacy practices covered in this Policy and the Privacy Shield Principles with respect to Personal Information transferred from the EEA/EU, the Privacy Shield Principles shall prevail. To learn more about the Privacy Shield, the Privacy Shield Principles, the requirements for participating companies, such as MiTek, and to view MiTek’s certification, please visit https://www.privacyshield.gov.

MiTek is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. MiTek complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, MiTek is subject to the regulatory enforcement powers of the U. S. Federal Trade Commission. In certain situations, MiTek may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

MiTek respects and protects individual privacy. This Privacy Shield and Swiss Safe Harbor Privacy Policy describes the principles MiTek follows with respect to transfer of Personal Information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway), and from Switzerland, to the United States.

MiTek also participates in the U. S. -Swiss Safe Harbor Framework (“Swiss Safe Harbor Framework”) and has certified that it adheres to its’ privacy principles (“Safe Harbor Privacy Principles”) of notice, choice, onward transfer, security, data integrity, access, and enforcement. MiTek’s practices with respect to each of these Safe Harbor Privacy Principles are detailed below. If there is a conflict between the privacy practices covered in this Policy and the Safe Harbor Privacy Principles with respect to Personal Information transferred from Switzerland, the Safe Harbor Privacy Principles shall prevail. To learn more about the Swiss Safe Harbor Framework, the Safe Harbor Privacy Principles, the requirements for participating companies, such as MiTek, and to view MiTek’s certification, please visit http://www.export.gov/safeharbor/.

DEFINITIONS

Agent means any third party that collects or uses Personal Information under the instructions of, and solely for, MiTek or to which MiTek discloses Personal Information for use on MiTek’s behalf.

Personal Information means information that identifies or can be used by or on behalf of MiTek to identify an individual. This may take the form of an employee identification number, name, title, office/work location, e-mail address, payment information, telephone number(s), photo, department, reporting hierarchy, or home address. Personal Information does not include “Usage Data,” which we define as encoded information, aggregate information, anonymized information, or information that is publicly available and not combined with non-public personal information.

Sensitive Personal Information means Personal Information that may reveal race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns mental or physical health or sexual orientation, that regards social security benefits, information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings, or biometric information. In addition, MiTek will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.

NOTICE: If MiTek collects Personal Information directly from individuals in the EEA or Switzerland, it will inform these individuals about the purposes for which it collects and uses Personal Information about them, the types of non–Agent third parties to which MiTek discloses that information, the choices and means, if any, MiTek offers individuals for limiting the use and disclosure of Personal Information about them, and how to contact MiTek with respect to any questions or concerns about MiTek collection or use of such Personal Information. This notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to MiTek, or as soon as practicable thereafter, and in any event before MiTek uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a non-Agent third party. If MiTek receives Personal Information from its affiliated companies, business units, or other entities in the EEA or Switzerland, MiTek’s use and disclosure of such data will adhere to the notices provided by such entities and the choices made by the individuals to whom the Personal Information relates.

CHOICE: For Personal Information, MiTek will offer individuals the opportunity to choose (opt-out) from: (a) disclosure of their Personal Information to a non-Agent third party, or (b) use of their Personal Information for purposes that are incompatible with the purposes for which the Personal Information was originally collected or as subsequently authorized by the individual. For Sensitive Personal Information, MiTek will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-Agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. MiTek will provide individuals with reasonable mechanisms to exercise their choices.

ACCOUNTABILITY FOR ONWARD TRANSFERS: MiTek may transfer Personal Information to its Agents, such as an email service provider, platform hosting provider, payment processor, vendor, and service providers, as required for normal business operations. If MiTek transfers data to its Agents, MiTek will attempt to ascertain that such Agents are providing at least the same level of privacy protection as is required by the Privacy Shield Principles and will take reasonable and appropriate steps to ensure that any such Agent is processing Personal Information in a manner consistent with MiTek’s obligations under the Privacy Shield. MiTek will require any Agents to notify MiTek if that Agent determines it is unable to provide the same level of privacy protection as is required by the Privacy Shield Principles. To the extent that MiTek is made aware of the unauthorized processing of Personal Information, it will take reasonable and appropriate steps to stop and remediate the unauthorized processing. MiTek remains potentially liable under the Privacy Shield Principles if Agents that it engages to assist with processing Personal Information on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless MiTek proves that it is not responsible for the event giving rise to the damage.

ACCESS: We acknowledge EEA/EU individuals have the right to access their Personal Information to correct or delete it. Where MiTek collects Personal Information directly from such individual(s), MiTek will, upon request, grant such individual(s) access to the Personal Information that it holds about them. In addition, if an individual believes that his/her Personal Information is, or has become, unreliable, inaccurate, incomplete, untimely, or irrelevant, MiTek will take all reasonable steps necessary to ensure that his/her Personal Information is reliable, accurate, complete, timely, and relevant to its intended use, except where the burden or expense of providing access to such review, revision, correction, or update would be disproportionate to the risk to the individual’s privacy, where the rights of other persons would be violated, where the organization’s confidential commercial information would be compromised, where it would interfere with the execution or enforcement of the law or with a private cause ofaction, or where it would breach a legal or other professional privilege or obligation. MiTek may verify the individual’s identity and ask for other information to respond to the individual’s request.

SECURITY: MiTek will take reasonable and appropriate precautions including physical, technical, and administrative measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, tampering, alteration and unauthorized destruction. MiTek follows generally accepted security standards in our operations to protect the security of your Personal Information, both internally and from outsiders, and to ensure the integrity of the Personal Information it processes, taking into account the relative risks involved and the nature of the Personal Information in question. Unfortunately, with any transmission over the Internet, there is always some element of risk involved.

DATA INTEGRITY AND PURPOSE LIMITATION: MiTek will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. MiTek will take reasonable steps to ensure that Personal Information is reliable, accurate, current, complete, and relevant to its intended use.

ENFORCEMENT: MiTek will audit its privacy processes and practices to verify compliance with this Policy and will correct deficiencies. Any MiTek employee that MiTek determines has intentionally violated this Policy will be subject to disciplinary action up to and including termination. Further, MiTek is subject to the investigatory and enforcement powers of the U. S. Federal Trade Commission.

DISPUTE RESOLUTION: Individuals can resolve their questions or complaints regarding use of Personal Information in accordance with this Policy. MiTek encourages interested persons to raise any concerns using the MiTek contact information provided below. MiTek will investigate and attempt to resolve any complaints and disputes regarding use or disclosure of Personal Information in accordance with the principles contained in this Policy. If a complaint or dispute cannot be resolved through MiTek’s internal process, MiTek has agreed to the following dispute resolution procedures:

1. For disputes involving Personal Information received by MiTek from Switzerland, MiTek has agreed to cooperate with the Swiss FDPIC;

2. For disputes involving employment-related Personal Information received by MiTek from the EEA, MiTek has agreed to cooperate with EEA/EU data protection authorities (“DPAs”) and to participate in the dispute resolution procedures of the panel established by the European data protection authorities.

3. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U. S. -based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Please note that if your complaint is not resolved through these channels, under limited circumstances, as more fully described on the Privacy Shield website, a binding arbitration option may be available before a Privacy Shield Panel.

Limitation on Application of Principles: Adherence by MiTek to the Privacy Shield Principles may be limited (a) to the extent required to respond to a legal or ethical obligation (including conducting internal audits or investigations as part of its compliance with applicable law); (b) to the extent necessary to respond to lawful requests by public authorities, including meeting national security and/or law enforcement requests; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

MITEK CONTACT INFORMATION: Parties may address their questions, comments, or complaints to the MiTek at the following address:

MiTek USA, Inc.
Attn: Privacy Manager
16023 Swingley Ridge Road
Chesterfield, MO 63017 USA

UPDATES TO THIS POLICY: We reserve the right to revise or update our policies and this Privacy Statement at any time, consistent with the requirements of the Privacy Shield and Swiss Safe Harbor Framework. The “Effective Date” below reflects the date of the most recent revisions. The most current version of this Policy can be reviewed by clicking on the “PRIVACY SHIELD AND SWISS SAFE HARBOR PRIVACY POLICY” link located at the bottom of each of our pages associated with the Sites. We encourage you to periodically review this link for the latest information on our privacy practices. Any update to this Policy will become effective when we post the revised Policy on the web page.