This Privacy Policy applies to how SpotOn processes Consumer personal information through SpotOn websites, Mobile Apps, the SpotOn Portal, a SpotOn device located at a Merchant, or when a Consumer submits or uploads information through any Merchant (together, the “Services”) provided by SpotOn Transact, LLC (“SpotOn,” “we,” “us” and “our”) to Consumers.
Consumers are individuals who:
use one or more of SpotOn’s mobile apps (“SpotOn Mobile”),
interact with SpotOn’s technology used at Merchants’ sites (such as tablets and point-of-sale devices) where a Merchant uploads your information to the “SpotOn Access Portal” to make appointments or reservations, to purchase goods and services from a merchant through SpotOn, or to provide information to third party delivery services,
participate in Loyalty Programs (participate in a merchant’s loyalty program or to receive messages and special offers from a merchant),
Use Teamworks labor management products, or
visit a SpotOn website (a “SpotOn Website” or a social media site, blog or related domain) or application. Please note, the SpotOn website is not intended for use by Consumers as it is our Merchant business to business website however, when you visit our Website, we will collect information as described in our Cookies and Tracking Technologies section.
SpotOn is only available in the United States and Canada.
For your information, each Merchant has agreed with SpotOn to treat information relating to Consumers that it obtains from SpotOn or as a result of the Merchant’s use of SpotOn technology and Services as described in the Merchant Terms. This Privacy Policy does not apply to any use of your information by a Merchant unless provided otherwise in this Policy. SpotOn is not responsible for the privacy policies or data practices of our Merchants, who may maintain separate policies and practices. If you are a SpotOn Merchant, please see the Merchant Privacy Policy.
This Privacy Policy is incorporated into and is a part of the User Terms of Service (“User Terms”). We encourage you to read this entire Privacy Policy before using a SpotOn Service. Do not use a SpotOn Website, SpotOn Mobile, a SpotOn device located at a Merchant, or any other SpotOn Access Portal if you are unwilling to accept the User Terms or acknowledge this Privacy Policy. By using SpotOn Access Portals or the Services or submitting information to SpotOn or using SpotOn’s services, you acknowledge your understanding of the collection, storage, use, and disclosure of that information in accordance with this Privacy Policy.
“Data” includes both Non-Personal Information and Personally Identifiable Information
“Merchant” is a business that offers SpotOn products and services
“Non-Personal Information” is any information that is not Personally Identifiable Information (defined below). Non-Personal Information includes, without limitation, Personally Identifiable Information that has been anonymized
“Participant Data” is Personally Identifiable Information that relates to activities you engage in offline that relate to the Services, such as which Offers you respond to (for example, by purchasing the goods or services that are the subject of the Offer) and loyalty rewards you earn from offline purchases, your reservations and appointments, your spending habits, and other services that SpotOn may make available to you
“Personal Data.” “Personal Information,” “Personally Identifiable Information” or “PII” shall have the same meaning as determined by applicable law but includes only information we receive from your use of our Services such as name, address, telephone number and other personal information you provide us
“Service Provider” or “Third-Party Providers” means a separate legal entity that processes personal data on SpotOn’s behalf.
“SpotOn Access Portal” refers to the system or technology used to enter customer information into SpotOn products, services into the SpotOn Point of Sale System (POS).
Why does SpotOn Collect Personal data?
SpotOn collects data from Merchants and Consumers to (1) provide the SpotOn products and services, (2) monitor, prevent and detect fraudulent payment transactions and other fraudulent activity on the SpotOn platform, (3) comply with legal or regulatory obligations applicable to the financial sector to which SpotOn is subject, and (4) analyze, develop and improve SpotOn products and services.
We provide our Services to third parties such as delivery apps and card issuers to support their services such as when you place an order with them. We may also manage points or rewards on behalf of and at the direction of our Merchants. We may also receive personal information from Third Party Service Providers such as order details and contact information to process transactions, reservations or supporting other services you use.
SpotOn Accounts: You may register an account at a participating Merchant’s location or sign up for a SpotOn account by downloading the app from an app store. We will ask for an email and password. Once you create your account and login, you may add your phone number to expedite the check-in service. After you login, you will be asked to share your location. If you do not share your location, we cannot identify participating Merchants. After you register, you may be offered the opportunity to receive Notes and Offers via Facebook, Twitter or other Social Media Tools, and to participate in various programs to earn additional benefits. If you sign up to receive text messages, please refer to our SMS Terms located in our SpotOn UserTerms of Service.
Point of Sale (POS): We may collect additional information, depending on how a merchant configures its SpotOn account. This information may include: your email address or phone number, for example, if you choose to receive an electronic receipt or opt-in to receive marketing communications; your marketing preferences, such as whether you wish to receive marketing communications or newsletters; information about your participation in a merchant’s loyalty program, if offered and if you choose to participate; other information you choose to enter into such as your birthdate, interests or preferences, reviews, and feedback.
We collect information about transaction(s), which may include personal information. Transaction information includes the payment card used, name associated with the payment card, electronic signature, name, and location of the merchant at which the transaction occurred, date and time of the transaction, transaction amount, and information about the goods or services purchased in the transaction. SpotOn utilizes Service Providers for Services provided by us for processing and transmitting payments, and storing your cardholder data. SpotOn does not transmit or store your cardholder data at any time during the process.
Special Note on Online Orders: We may collect additional information on consumers that are ordering through a merchant’s website to process a transaction including name, phone number and address for delivery or carry-out services. We may also collect additional location and device information on our order check-out pages as part of our fraud prevention efforts.
Loyalty Programs. After you register with SpotOn (directly or through a SpotOn Access Portal) or are registered by a Merchant, you may receive “Offers,” defined as special promotions or offers from one or more Merchants. Such Offers may be sent to you automatically via email, mobile communications (e.g., SMS text messaging, mobile notifications), Facebook, Twitter or other social media. You may be able to post those Offers on your own Facebook page to share with your friends. SpotOn may automatically keep track of those choices and associate them with the registration information you provided or that was provided for you by a Merchant, including your Personal Information you (or a Merchant on your behalf) may have provided.
SpotOn may use your Personal Information for a number of purposes, including keeping track of rewards or loyalty points (if offered by the Merchant), categorizing you with respect to your response to Offers and rewards programs of each Merchant, and marketing goods or services of Merchants and SpotOn as described above. SpotOn will offer you the option not to receive such marketing messages from SpotOn. We also require Merchants to agree to offer you an option not to receive marketing messages if they have permission to use the data.
SpotOn may provide information to certain Service Providers such as delivery services to fulfill orders. Consent to sharing will be provided if you register for their service. The Service Provider may also return data regarding orders, delivery fulfillment, ratings, transactions, reward redemption or points back to SpotOn and/or our merchants to facilitate transactions, provide analytics and reporting and/or to enhance our products and services.
We and our Service Providers may collect information about individuals that is publicly available, including by searching publicly accessible government lists of restricted or sanctioned persons (such as the Specially Designated Nationals And Blocked Persons List), public records databases (such as company registries and regulatory filings), and by searching media and the internet for compliance purposes. We and or our third party verification providers may also collect information from private or commercially available sources, such as by requesting reports or information from credit reference, fraud prevention agencies, or identity verification services to complete anti-money laundering requirements to the extent permitted under applicable law.
We may also maintain pages for our company and our products and services on a variety of third-party platforms, such as LinkedIn, Facebook, Twitter, YouTube, Instagram, and other social networking services. When individuals interact with our pages on those third-party platforms, the third-party’s privacy policy will govern your interactions on the relevant platform. If the third-party platform provides us with information about our
pages on those platforms or your interactions with them (e.g. for lead generation purposes), we will treat that information in accordance with this Privacy Policy.The Site or our online Services may send a “cookie” to your computer. A cookie is a small file, typically of letters and numbers, downloaded onto a device such as a computer or mobile device when you access our websites. For more information about cookies or local storage, including how to see what cookies have been set and how to manage, block and delete them, see: http://www.allaboutcookies.org/. A cookie cannot read data off your hard disk or read cookie files created by other sites. Cookies do not damage your system. Cookies allow us to recognize you as a user when you return to the Site or use the online Services using the same computer and web browser. We use cookies to identify which areas of the Site or online Services you have visited. We also may use this information to better personalize the content you see on the Site or online Services. SpotOn does not store unencrypted Personal Information in the cookies. We also do not link Non-Personal Information from cookies to your Personal Information.
To help us optimize the Site or for marketing purposes, we may allow other authorized third parties to place or recognize unique cookies on your browser. Any information provided to third parties through cookies will be for enhancing your user experience by providing more relevant marketing of our Services.
Some browsers may allow you to manage the storage of cookies on your device. If supported by your browser, you may set your browser to refuse all cookies (or, sometimes all third-party cookies) or to alert you when a cookie is placed. However, if you select these settings, you may be unable to access certain parts of the Site or the online Services. Unless you have adjusted your browser setting to refuse cookies, the Site and online Services will issue cookies. For more information about how to manage your cookies preferences, use the ‘help’ menu of your web browser or explore the customer support sections of your web browser. To opt-out of all cookies or certain advertising cookies, visit the company website for your browser for instructions.
You can opt-out of receiving personalized ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”) or who follow the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising using their respective opt-out tools. The NAI's opt-out tool can be found here: http://www.networkadvertising.org/choices/. and the DAA's opt out tool can be found here: http://www.aboutads.info/choices/.
In addition, your mobile devices may offer settings that enable you to make choices about the collection, use, or transfer of mobile app information for online behavioral advertising (for example, Apple iOS’ Advertising ID and Google Android’s Advertising ID). Please note that opting out does not prevent the display of all advertisements to you.
We may use embedded pixel technologies on selected pages for the purposes of identifying unique user visits to the Site as opposed to aggregate hits. In addition, embedded pixels or other technologies may be used in emails to provide information on when the email was opened to track marketing campaign responsiveness; information collected using these technologies may be associated with your email address.
We may use flash cookies, also known as “local shared objects,” on the Site if it employs or in the future employs flash technology. Flash cookies are small files similar to browser cookies and are used to remember the site’s settings to personalize the look and feel of the site. Like normal cookies, flash cookies are represented as small files on your computer.
We may also use a tracking technique that employs embedded URLs to allow use of the Site without cookies. Embedded URLs allow limited information to follow you as you navigate the Site but are not associated with your Personal Information and is not used beyond the session.
The Site may include widgets, which are interactive mini programs that run on our Site to provide specific services from another company (e.g., links to bookmarked sites). Some information, such as your email address, may be collected through the widget. Cookies may also be set by the widget to enable it to function properly. Information collected by this widget is governed by the privacy policy of the company that created it.
The online advertising industry provides websites through which you may opt out of receiving targeted ads from parties that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others. You must separately opt out in each browser and on each device. Please note you will continue to receive transactional data and general ads.
Many Internet browsers allow you to adjust your cookie preferences or delete existing cookies. If you set your browser to reject cookies, you should be aware that certain browser-based app or website features, promotions or services may not be available to you or may not function correctly.
Certain Internet browsers may enable you to set "do not track" preferences to limit the collection of personally identifiable information about your online activities over time and across
third-party websites or online services. Mercari’s systems do not respond to Internet browser "do not track " signals or similar mechanisms.You provide Personal Information when you register for the Services through any SpotOn Access Portal, including a SpotOn Website or SpotOn Mobile (for example, on the registration page or through an upload you authorize), collected on Hardware and technology we provide to enable services and a Merchant may send SpotOn such information for you. Except as otherwise stated, SpotOn may use Personal Information collected for:
SpotOn may provide Personal Information to certain Merchants with which (or by which) you are registered, and that have been permitted such information access by SpotOn. SpotOn may also share your Personal Information with Service Providers to support the Services we provide.
SpotOn may provide aggregate statistics or information about its customers, sales, trends, loyalty program usage, online traffic patterns, related information or other statistical de-identified or aggregated information to third parties, but these statistics or information will not include any Personally Identifiable Information (“Non-Identifying Information”). Non-Identifying Information is also used by SpotOn and/or third parties we contract with to troubleshoot, operate and improve SpotOn Websites, SpotOn Mobile and SpotOn technology, to assist us with marketing or ad placement, to cooperate with law enforcement activities or legal orders, to protect our rights (including enforcing the Merchant Terms and User Terms) or to address or prevent illegal or harmful activity. In addition, SpotOn may use all information submitted by Consumers that SpotOn collects about them that is Non-Identifying Information in any way SpotOn deems useful, including publishing statistics such as those described above to promote SpotOn or its Services.
SpotOn may use third-party analytics service providers to help us with our online services, such as Google Analytics, and Facebook. The analytics providers that administer these services use technologies such as cookies, web beacons, and web server logs to help us analyze how you use our online services. We may disclose your site-use information (including IP address) to these analytics providers, and other service providers who use the information to help us figure out how you and others use our online services.
SpotOn strives to provide Consumers with choices regarding the information they provide. SpotOn has created mechanisms to provide Consumers with the following control over their information:
(i) You may access, delete, and modify the Personal Information you submitted through a SpotOn Access Portal, or that was submitted to SpotOn on your behalf by a Merchant, as follows: you may modify the information you submitted when you registered, or when a Merchant registered you, by going to the applicable SpotOn Website or SpotOn Mobile. You may opt out of messages from SpotOn or revoke your consent to such messages, by turning off notifications for SpotOn Mobile or by choosing the opt-out option provided in any messages. If you want to stop receiving all messages through the Services, you will need to delete the SpotOn App from your device, visit each social media company through which the you chose to have the Services provided (e.g., Facebook, Twitter, etc.) and delete SpotOn from each such social media company, and choose the opt-out option provided in messages sent via email.
SpotOn keeps track of Consumers’ transactions with Merchants or with services provided by SpotOn as well as communications about Merchants that Consumers make through SpotOn technology (e.g., posting Offers to a Facebook page, sending Offers to friends).
Marketing messages from SpotOn will contain an option for the Consumer to choose not to receive such messages in the future. When and if marketing messages from Merchants or other or third parties are permitted, SpotOn intends to require the Merchant or other third party to agree to allow Consumers to choose not to receive such messages. SpotOn will not be responsible for assuring that Merchants or other third parties comply with such commitments.
If a Consumer does not wish SpotOn to collect cookies, he or she may set the browser to refuse cookies, or to alert the user when cookies are being sent. Please note that some parts of the SpotOn Services may then be inaccessible or may not function.
When and if permitted by SpotOn, such Merchants may use information to send you messages, independent of the Services, about their goods and services and about the goods and services of other merchants. If you do not wish to receive such messages you may opt out of receiving them by choosing the opt-out option provided in such messages. All Merchants granted such permission by SpotOn will have agreed not to provide your Personal Information to third parties except as described in the Merchant Terms. Merchants have also agreed to abide by the rules and obligations under the CAN-SPAM Act of 2003 (15 U.S.C. § 103, et seq). SpotOn is not responsible for assuring that Merchants comply with these commitments.
We retain your Personal Information for as long as necessary to fulfill the purpose for which it was collected and to comply with applicable laws. We use reasonable security precautions to protect your information while in storage.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and applicable legal requirements.
SpotOn works hard to protect the Personal Information of Consumers, using both technical and procedural methods to maintain the integrity and security of our databases. These include the use of SSL encryption, firewalls, administrative access level controls and employee training. Consumers should keep in mind, however, that no Internet transmission or data storage is ever completely secure or error-free. While SpotOn believes it uses commercially reasonable security procedures, it cannot guarantee the security of any information submitted by Consumers or information gathered about Consumers or information stored by SpotOn
Each Merchant has agreed to abide by this Privacy Policy. SpotOn is not responsible for Merchants’ compliance with this Privacy Policy or for Merchants’ security policies and practices. SpotOn is not responsible for the actions of any third party, including but not limited to any Merchant, Facebook, other social media sites or other sites, with whom information about you may be shared or who may otherwise obtain such information.
The safety and security of information of each Consumer also depends on the Consumer. You should never share your SpotOn passwords, or any other password (including passwords you use with Merchants, Facebook or any other social media site), with anyone else, and should notify SpotOn, or any other relevant provider site if you believe your password security has been breached. Remember to log off of each SpotOn Website and SpotOn Mobile before you leave your computer or mobile device.
The SpotOn Websites, SpotOn Mobile or other sites through which you may use the Services may contain links to other sites and/or resources over which neither SpotOn nor Merchants have any control. SpotOn makes no representations or warranties with respect to the content, ownership, or legality of any such linked sites. Links to third-party sites are provided solely as a convenience to you and should not be construed as an affiliation with or endorsement by SpotOn or any Merchant of such third parties or any content, items, or services on third-party sites. Access and use of such other sites, including the content, items, or services on those sites, solely at the risk of the user, and SpotOn has no responsibility or liability resulting from your access or use of such other sites. These linked sites may collect personal information from you when you enter their site. Any such collecting of information is not subject to the control of SpotOn. To ensure protection of privacy, you should always review the privacy policies of the sites you visit when linking from a SpotOn Website, SpotOn Mobile or any other site associated with the Services.
The SpotOn Website, SpotOn Mobile and the Services are only intended for persons 18 years of age or older.
SpotOn fully complies with COPPA requirements. SpotOn will not knowingly collect Personally Identifiable Information from site visitors under the age of 13. If we learn that any information we collect has been provided by a child under the age of 13, we will take all reasonable measures to delete such information from its databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law).
If you have knowledge that a child 13 years of age or younger has submitted Personally Identifiable Information to us, please contact us and we will delete the Personal Information collected belonging to that child by sending an email to privacy@spoton.com. The parent or guardian will be required to provide verification of his/her identity and authority related to any request before we can disclose any information that was collected, otherwise all data will be deleted once confirmed.
Merchants who use SpotOn’s services may sell goods or services for children that are intended to be purchased by adults. Merchants have agreed that they will not knowingly collect such information. SpotOn is not responsible for assuring that Merchants comply with that commitment.
SpotOn fully complies with the federal CAN-SPAM Act. You can always opt out of receipt of further email correspondence from us.
This Privacy Policy for California residents supplements the information contained above in our general Privacy Policy and applies solely to Consumers who reside in the State of California. Any inconsistent terms in any other sections of the Privacy Policy will be superseded by this Section for California residents.
To the extent applicable to SpotOn, under the CCPA, California residents are granted the following rights:
How to Submit a Request
To request this information, please submit a verifiable consumer email request to: Privacy@spoton.com and submit your request in the body of the email with the subject heading: “CCPA Consumer Request.”
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. We are not required to provide you with Personal Information more than twice in a 12-month period.
We will not be able to respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
We will try to respond to your request within forty-five (45) days of receipt of your written request. If we require more time (up to 90 days), we will inform you of the extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is machine-readable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
When receiving a request, we will verify that the individual making the request is the resident to whom the Personal Information subject to the request pertains. California residents may exercise their rights themselves or may use an authorized agent to make requests to disclose certain information about the processing of their Personal Information or to delete Personal Information on their behalf. If you use an authorized agent to submit a request, we may require that you provide us additional information demonstrating that the agent is acting on your behalf.
We may collect the following Personal Information. Personal Information does not include public information available from government records, de-identified or aggregated information.
We retain your Personal Information for as long as necessary to fulfill the purpose for which it was collected and to comply with applicable laws. We use reasonable security precautions to protect your information while in storage.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and applicable legal requirements
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services, except to the extent that providing the Services requires the disclosure of Personal Information that you have decided not to disclose or allow us to use for the purpose of providing the Services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Nevada law (SB 220) permits customers in Nevada to opt-out of the sale of certain kinds of personal information. A sale under Nevada law is the transfer of this personal information to third parties for monetary consideration so these third parties can then resell or license the sold information. We do not sell your Personal Information to third parties as defined in Nevada law. If you are a Nevada resident and wish to opt-out of the sale of your personal information, should we change our practices in the future, you must send a request by email to privacy@SpotOn.com.
We set forth above in our Privacy Policy the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared.
If you are a Virginia Consumer and would like to exercise your rights pursuant to the Virginia Consumer Data Protection Act (VCDPA), and any implementing regulations adopted thereunder, please send a request by email to privacy@SpotOn.com to submit a request.
Virginia Consumers have the following rights, all subject to the meanings and exceptions set forth in the VCDPA:
To confirm whether we are processing your Personal Data and request to access such data ("Right to Access").
That we correct inaccurate Personal Data we hold about you ("Right to Correct").
That we delete the Personal Data provided by you or obtained about you ("Right to Delete").
To obtain a copy of the Personal Data previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability ("Right to Obtain").
To opt- out of the processing of your Personal Data for the purposes of targeted advertising ("Right to Opt-Out of Targeted Advertising").
VCDPA Appeals
Pursuant to the VCDPA, if, for any reason, you would like to appeal our decision relating to your request, you have the right to submit an appeal and can do so by sending a request by email to privacy@SpotOn.com to submit a request or call us toll-free at 877-814-4102 to submit a request. Please include your full name, the basis for your appeal, and any additional information to consider.
Consumers may be allowed to post public comments, including comments about Merchants and their goods and services, on a Merchant’s Facebook page or on other social media. Such capability is offered by Facebook or another social media company, and is subject to the privacy policy of Facebook or such other social media company. We encourage you to review such privacy policies before submitting any such comments. Consumers may also be allowed to post similar comments on a SpotOn Website or SpotOn Mobile. Any messages posted in public access portions of Facebook, other social media sites a SpotOn Website or SpotOn Mobile may be read, saved, used and/or distributed by such social media companies, SpotOn, Merchants and any other users of the sites. Any such postings may be re-posted by any of such users on other websites, used in blogs, etc., and may appear in web searches. SpotOn cannot control who views information so posted or what they do with it, so care should be used when sending any personal information to any public access site. SpotOn also cannot control and is not responsible for the accuracy, truthfulness or tastefulness of any information posted by other users on Facebook or other social media sites, on a SpotOn Website, SpotOn Mobile or on any other public access site.
If you have any questions regarding our privacy practices or this Privacy Policy, or to request this Privacy Policy in another format such as PDF, please contact us at:
You may also contact the Merchant to which such questions, comments or concerns relate. Please review this Privacy Policy carefully.
SpotOn reserves the right to update this Privacy Policy at any time. If this Privacy Policy is materially changed, the revised policy, or a notice that the policy has been revised, will be posted on the applicable SpotOn Website and SpotOn Mobile. You are responsible for periodically reviewing the Privacy Policy, and should do so frequently, especially before you provide any Personally Identifiable Information. When SpotOn changes this Privacy Policy, we will also revise the “last updated” date at the end of this Privacy Policy. If SpotOn updates this Privacy Policy, continued use of the Services (following the posting of the revised Privacy Policy) means that you accept and agree to the terms of the revised Privacy Policy. SpotOn recommends that you periodically review this Privacy Policy.