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Privacy policy | © Working the Future Ltd 2018

 

WEBSITE TERMS OF USE & PRIVACY POLICY

PLEASE READ THESE TERMS CAREFULLY BEFORE USING OUR SITE
 
TERMS OF USE

These terms tell you the rules for using our website www.workingthefuture.com (our site).
 
WHO WE ARE AND HOW TO CONTACT US
Our site is operated by Working the Future Limited (We). We are registered in England and Wales under company number 10512378 and have our registered office at 42 Longfield Drive, Amersham, Buckinghamshire, HP6 6HE, United Kingdom.  To contact us, please email info@workingthefuture.com.
 
BY USING OUR SITE YOU ACCEPT THESE TERMS
By using our site, you confirm that you accept these terms of use and that you agree to comply with them. If you do not agree to these terms, you must not use our site. We recommend that you print a copy of these terms for future reference.
 
THERE ARE OTHER TERMS THAT MAY APPLY TO YOU
Our Privacy Policy also applies to your use of our site. Our Privacy Policy sets out the terms on which we process any personal data we collect from you, or that you provide to us. By using our site, you consent to such processing and you warrant that all data provided by you is accurate.
 
WE MAY MAKE CHANGES TO THESE TERMS
We amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time. These terms were most recently updated on 22nd May 2018.
 
WE MAY MAKE CHANGES TO OUR SITE
We update and change our site from time to time.
 
WE MAY SUSPEND OR WITHDRAW OUR SITE
Our site is made available free of charge.
We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our site for business and operational reasons.
You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and

conditions, and that they comply with them.
 
HOW YOU MAY USE MATERIAL ON OUR SITE
We are the owner or the licensee of all intellectual property rights in our site including in our domain names and in the content and material published on it.
Those works are protected by copyright laws and treaties around the world. All such rights are reserved. Our brand and some of the content on our site is further protected by trademark law.
 
To the extent permitted by law, you may print off one copy or download extracts of pages from our site for your personal, strictly non-commercial use. You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way and you must not use any copy, content including illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text or without clear attribution to us as the owners and authors of content on our site.
 
You must not use any part of the content on our site otherwise than as provided in the paragraph above or for commercial purposes without first obtaining a licence to do so from us or our licensors, which is subject to our unfettered discretion (and that of our licensors).
If you print off, copy or download any part of our site in breach of these terms of use, you will be infringing our proprietary and other rights and your right to use our site will cease immediately. You must, at our option, return or destroy any copies of the materials you have made and provide clear evidence that you have done so.
 
DO NOT RELY ON INFORMATION ON THIS SITE
The content on our site is provided for general information only. It is not intended to amount to advice on which you should rely or to form any business relationship between us. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site. Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up to date.
 
WE ARE NOT RESPONSIBLE FOR WEBSITES WE LINK TO
Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them. We have no control over the contents of those sites or resources.
 
OUR RESPONSIBILITY FOR LOSS OR DAMAGE SUFFERED BY YOU
We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.
 
We do exclude all implied conditions, warranties, representations or other terms that may apply to our site or any content on it.
 
In no event will We, our officers, employees, agents or contributors to this website be liable for any loss or damage, whether direct, indirect, special, punitive, incidental, exemplary, consequential or otherwise and whether arising in contract, tort (including negligence), breach of statutory duty or otherwise, even if foreseeable or if we’ve been advised of the possibility of such liability arising under or in connection with:

access to, use of or inability to use or access our site; or

use of or reliance on any content or material displayed on our site.

 
In particular, we will not be liable for:

  • loss of profits, sales, business, data or revenue;
  • business interruption;
  • loss of anticipated savings; or
  • loss of business opportunity, goodwill or reputation.

 
WE ARE NOT RESPONSIBLE FOR VIRUSES AND YOU MUST NOT INTRODUCE THEM
We do not guarantee that our site will be secure or free from bugs or viruses. You are responsible for configuring your information technology, computer programmes and platform to access our site. You should use your own virus protection software.
 
You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.
 
RULES ABOUT LINKING TO OUR SITE
You may link to our home page, provided you do so in a way that is fair, legal, appropriate to our business and does not damage our reputation or take advantage of it. You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.
 
You must not establish a link to our site in any website that is not owned by you. Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page. We reserve the right to refuse applications to link to our site or withdraw linking permission without notice.
 
If you wish to link to or make any use of content on our site, please contact info@workingthefuture.com.
 
WHICH COUNTRY’S LAWS APPLY TO ANY DISPUTES?
These terms of use, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.
 
 
PRIVACY NOTICE
 
INTRODUCTION
Working the Future respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
 
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
 
1. IMPORTANT INFORMATION AND WHO WE ARE
 
PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Working the Future Limited collects and processes your personal data as a customer or potential customer through your use of our services, your use of this website or through our marketing activities, including any data you may provide through this website when you sign upto our newsletter or purchase a product or service.
 
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
 
CONTROLLER
This privacy notice is issued on behalf of Working the Future Limited, so when we mention ”Working the Future”, “we”, “us” or “our” in this privacy notice, this is to whom we refer.
 
Working the Future Limited is the controller and responsible for your personal data and this website and any marketing activity by Working the Future.
 
We have appointed a manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
 
CONTACT DETAILS
Our full details are:
 
Full name oflegal entity:                                   Working the Future Limited
Name or title of data privacy manager:         Patrick Lodge
Postal address:                                                   42 Longfield Drive, Amersham, Buckinghamshire HP6 5HE
 
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
 
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES 
This version was last updated on 21st May 2018.
 
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
 
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-insand applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
 
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
 
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, title and gender.

 

Contact Data includes billing address, office address, office email address and telephone numbers.

 

Financial Data includes bank account and payment card details (if you have provided those to us).

 

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

 

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

 

Profile Data includes purchases or orders made by you, your interests, preferences, download history, and any feedback and survey responses.

 

Usage Data includes information about how you use our website, products and services.

 

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 
We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
 
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions andoffences.
 
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
 
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:

 

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • subscribe to our service or newsletters or other publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • request to be invited to our events or
  • give us some feedback.

 

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details

 

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

 

Technical Data from the following parties:

(a) analytics providers [such as Google based outside the EU];
(b) advertising networks [such as AdRoll based inside OR outside the EU]; and
(c) search information providers [such as Google based inside OR outside the EU].

 

Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

 

Identity Data and Contact Data from data brokers or aggregators such as CorpData based outside the EU.

 

Identity and Contact Data from publicly available sources such as Companies House, government websites and LinkedIn and which we may then aggregate together.

 

Identity, Contact, Financial, Transaction, Usage, Technical, Profile, Marketing and Communications Data from our staff who have been in contact with you for the delivery or potential delivery of services, invitation to our events or subscription of our newsletter.

 
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

 
See the table below to find out more about the types of lawful basis that we will rely on to process your personal data.
 
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
 
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.


Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
 
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
 
To register you as a new customer
(a) Identity
(b) Contact

Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, feesand charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

Necessary for our legitimate interests (to recover debts due to us)
 
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
 
To enable you to partake in a competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
 
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
 
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
  
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
 
To make suggestions and recommendations to you about goods or services that may be of interest to you, to invite you to events and send you our newsletters
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)
 
MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:


PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, offers, newsletters or events may be relevant for you (we call this marketing).
 
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you registered for a newsletter or event and, in each case, you have not opted out of receiving that marketing.
 
THIRD-PARTY MARKETING
We will not share your personal data with any third parties except where you have expressly provided consent.
 
OPTING OUT
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
 
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
 
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
 
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
 
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
 
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.
• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
 
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
 
6. INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.


Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.


Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
 
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
 
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 
8. DATA RETENTION


HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
 
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
 
Details of retention periods for different aspects of your personal data can be requested from us by contacting us.
 
In any event, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
 
In addition, when we rely on the legitimate interest lawful basis to process your data, we will keep the data until that legitimate interest subsists (unless another lawful basis continues to apply as per the table in paragraph 4).
 
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
 
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
 
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
There are further details in the Glossary. If you wish to exercise any of the rights set out above, please contact us.
 
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
 
WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
 
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
 
10. GLOSSARY
 
LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
 
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
 
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
 
EXTERNAL THIRD PARTIES

  • Service providers acting as processors based in the EEA or United States of America who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Service providers who provide market research services and data providers.

 
YOUR LEGAL RIGHTS

You have the right to:
 
Request access to your personal data (commonly known as a “data subject access request”).
 
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
 
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
 
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
 
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
 
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
 
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
 
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

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