Last updated: August 2021
1. ABOUT THIS DOCUMENT
2. OUR COMMITMENT
We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information that you entrust to us.
3. ABOUT US
4. OUR LEGAL BASES FOR PROCESSING
We will collect and process your personal information only when necessary for the purpose of lawful activities that are reasonably required for our business and in accordance with all applicable laws and applicable contractual obligations. More specifically, we will not process personal information unless at least one of the following requirements is met:
- You have given consent to the processing of your personal information for one or more specific purposes (for instance, to receive offers tailored to your interests, to be contacted in response to an enquiry)
- The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior to entering into a contract (for instance, when you request a quote from us);
- Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);
- Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip);
- Processing is reasonably required for our lawful business activity.
5. CHANGE OF PURPOSE
Unless allowed by applicable laws, we will only use your personal information for the purpose for which we obtained it, or for a purpose that is related to the original purpose. If you require an explanation as to how the processing for the new purpose is related to the original purpose, please contact us.
- There are some circumstances in which personal information may be processed for purposes that go beyond the original purpose for which the personal information was collected. When this is susceptible to be the case, we will make reasonable efforts to tell you in advance and request your consent when required.
- There are some circumstances where we may have other secondary purposes, for processing already existing data which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.
- We will adopt an aggregate data model that allows us derive aggregated data from your personal information. For example we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.
- If we combine or connect aggregated data with your other information so that it directly or indirectly identifies you, we shall process the combined data in accordance with applicable laws, including the Privacy Act 2020.
6.1 Our Customers
6.2 Examples Of Who This Policy Covers
6.3 When We Are Data Processor Only
6.4 Terms Used In This Policy
When we refer to "processing" of your personal information, this includes obtaining, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.
When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.
When we refer to our "websites", we mean all our present or future websites, including those at the following addresses, and any other website on which these terms appear: insightvacations.com/nz. References to our websites include: (a) our websites you visit through a web-browser or through an app; and (b) any community functionality and other functionality and services provided by us remotely which you access on or through our websites
When we refer to our "apps" we mean all of our present and future apps, including any apps which this policy is presented with, and references to our apps include (1) any native software application and any software that runs in a web browser, (2) any software that we provide for installation or use on a PC or on a mobile computer such as a tablet or phone, and (3) any community functionality and other functionality and services provided by us in or through the app, including remotely.
When we refer to "community functionality" this means any service or functionality we provide on or through our websites or apps, which enables you to upload, post or send any content or messages, or receive any content or messages, including any comment or review system, forum, feedback system, survey system, review system, blogging system, picture or video gallery functionality, messaging system, system for posting into other social media platforms such as Facebook or Twitter, and other interactive, social or community functionality.
When we refer to a "device" this includes a personal computer, computer server, tablet, phone, watch, or other computing device, used to access our websites or on which any of our apps is installed and run.
7. WHAT TYPES OF PERSONAL DATA WE PROCESS
We process your personal information in accordance applicable laws, including the Privacy Act 2020.
Our regulator is the New Zealand Privacy Commissioner: www.privacy.org.nz
8. WHAT TYPES OF PERSONAL DATA WE PROCESS
This section summarizes the types of personal information about you that we process:
8.1 Data Concerning You As An Individual
This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, and utility bills, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you (such as to verify you identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.
8.2 Business Related Information
If you are an individual associated with a business or other organisation that is our customer, then your personal information may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).
8.3 Enquiry And Booking Information
Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by you or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.
8.4 Performance Information
Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.
8.5 Survey Information
Information collected or generated out of any surveys we conduct.
8.6 Competition Information
Information collected or generated out of any competitions or promotions we run.
8.7 Account, Registration and Loyalty Information
Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.
Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.
8.9 Technical Information About Your Computer
We may collect technical information and data about or from the device accessing our websites or on which our apps are to be installed and run, including: (1) your IP address (a unique identifier allocated to your device for your connection to the internet); (2) your device's location; (3) your device details, including type of device (PC, tablet, smartphone, watch etc.), the make and model of device, and the features and functionality of your device; (4) the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; (5) your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); (6) your time-zone and language; (7) your browser plug-ins; (8) cookies previously set and information previously stored by us on your device; and (9) identifiers assigned to you by third-party advertising providers and web beacons you interact with. This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous.
8.10 Technical Information About Your Computer
We may collect information about your usage of your usage of our websites and apps, including: (1) any web-page you came from, identified as the referrer web page address by your web browser; (2) pages you visit; (3) features, services and functionality of our websites and apps you use; (4) website and app performance information, and errors encountered; (5) enquiries and searches undertaken; (6) services and products you viewed; (7) length of visit to websites and pages; (8) page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs); (9) data inputted into forms and fields; and (10) log-in / out information. This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous.
8.11 Community Data
Any content (including text, pictures and video), messages, and other data which you upload, post or send using any community functionality, and any content or messages sent to you personally from anyone else using any private messaging part of the community functionality.
9. HOW WE COLLECT OR GENERATE YOUR PERSONAL DATA
This section sets out the ways in which we may collect or generate personal information concerning you.
9.1 Automatic Capture
By visiting and using our websites and apps, your device may provide personal information, or your device may enable us to capture personal information, or store information and retrieve information previously stored. This includes: information which is automatically provided by your browser or device to our servers; information recorded on our servers about your interaction with and use of our websites and apps, including pages viewed and functionality used; information we capture or place on your computer or generate using cookies or other technologies on our websites or in our apps; and information you input into forms and fields on our websites or in our apps.
9.2 Data You Provide
Your personal information will include data you provide (or later amend), including: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website or in an app; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes any data you provide when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our websites or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; request sales and advertising information, including brochures; or upload, post or send anything using any community functionality.
9.3 User Generated Content (UGC)
We may process information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let Insight Vacations and TTC group companies to process this information in various initiatives. These could include any marketing activities such as:
- print materials;
- on our website;
- email activities;
- social posts;
- images on our trips;
- providing images to our trade partners to use on their websites, email marketing and other marketing initiatives;
- in our content feeds;
- sharing imagery in our content feeds, image repositories, via email and share with our trade partners via these methods;
- any other information provided to us by or in relation to you which concerns you as an individual.
9.4 Data Obtained From Third Parties
We may obtain personal information concerning you from third parties, including from: providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us; and posts and messages sent to you or addressed to you by other customers of ours using any community functionality.
9.5 Data Generated By Us
We and any suppliers or sub-contractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or data gained from your use of our websites and apps.
10. WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?
This section sets out the uses which we make of your personal information:
10.1 Operate Our Websites, Apps and Services
To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites, including all community functionality. This includes managing any accounts or registrations you have with our websites, apps, community functionality and services, and making changes to your settings and profile at your request.
10.2 Provide Information And Respond To Enquiries
To provide information to you about our websites, apps, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.
10.3 Bookings And Other Contracts
To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you.
To collect and make payments due and administer our accounts.
10.5 Communication With Customers
To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.
10.6 Record Keeping
To keep internal records and maintain reasonable archives, including concerning enquiries, bookings, contracts, travel services, and complaints; and for the purposes of disputes, legal proceedings and investigations.
10.7 Promotion, Management and Improvement of Our Businness
- to analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services;
- to carry out surveys and analyse the results;
- to run promotions and competitions;
- undertake product or customer research/development;
- to assist us in and help us to improve our sales;
- to carry out other business development and improvement activities;
- to provide training to our staff, sub-contractors and suppliers;
- editorial, advertising, and marketing processes, including sharing of photographs which you have voluntarily participated in during our Trips. Such photos may be shared across our social media channels such as Facebook, Instagram, Twitter or LinkedIn. These images will not be shared for any use other than to promote our Travel experiences. Please remove yourself from group photos organized by Trip Directors if you do not wish to be photographed;
For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.
10.8 Direct Marketing
To carry out direct marketing to you, in particular to identify you as a customer and to identify your product and service preferences and to provide personalized content and ads informing you of new or additional products, services, and/or promotions that may be of interest to you. We may engage in direct marketing via the following means depending on the details you have provided to us: text messages, phone calls, targeting you on social media platforms on your personal computer and mobile device, direct mail, post, web advertising, in third-party apps, in our apps. See section 11.1 for the types of products we may market to you this way.
To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.
10.10 Anything You Have Specifically Consented To
For any purpose which we have obtained your consent to.
10.11 Maintenance of Our Website and Apps
We may use your personal information to maintain and update our websites and apps. For instance, we may use technical information and data concerning your device to facilitate software maintenance and updates and product support.
10.12 Disclosure to Third-Party Service Providers
We may disclose your personal information to third parties where this is required for our business activity. Please see section 12 for more information.
11. USE OF YOUR PERSONAL DATAFOR DIRECT MARKETING
We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.
11.1 Direct Marketing By Us
Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us.
Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.
11.2 Direct Marketing By Third Parties
Where you have expressly consented to this, we may disclose your contact data (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this information to carry out direct marketing in their own right and will use it to send you marketing materials, advertisements and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.
12. DISCLOSURE OF YOUR PERSONAL INFORMATION
Disclosure of your personal information to third parties is one of the purposes for which we collect your data due to any of the following circumstances:
12.1 Credit Checks Etc.
We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.
12.2 Bookings And Performance Of Contracts
We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; to apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).
12.3 Suppliers Of Travel And Other Services
We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.
If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.
12.5 Business Function Outsourcing
Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis through third-party ad-tech vendors, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.
12.6 Community Functionality
Where any community functionality or facility on our websites and apps is clearly designed to make certain personal information public (e.g. posts you make to any public forum or reviews facility), or to have certain personal information communicated or made available to others (such as other customers of ours), then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, may be disclosed accordingly. Where you have agreed that certain of your personal information is non-confidential, then we may also disclose it for business promotion, management and improvement purposes.
12.7 Legal Requirements
We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.
12.8 Direct Marketing by Third Parites
We may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.
12.9 Customer Representatives
If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.
12.10 Business Acquirers
If our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business.
13. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL INFORMATION
Where we provide your personal information to a third party one of the following two circumstances will apply:
13.1 Processing on Our Behalf
13.2 Processing on Their Own Account
14. LOCATION OF YOUR PERSONAL INFORMATION
We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world to fulfill the purposes set out in this policy, for example to: (1) our overseas offices; (2) information processors (including operators of global travel distribution systems); (3) airlines, hotels and other travel service products; and (4) information technology and business service providers.
Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise collect, use and disclose that information anywhere in the world.
In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside of New Zealand, in particular by ensuring that the third party is either subject to comparable privacy laws as those of New Zealand or is otherwise required to safeguard your privacy to comparable standards. Where your personal information is still controlled by us or is being stored or otherwise collected, used or disclosed on our behalf, our security measures (as detailed below) will also apply.
Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.
15. KEEPING YOUR DATA SECURE
15.1 Our Security Measures
15.1.1 Our General Commitment
We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful collection, use and disclosure of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.
We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or sub-contractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.
15.1.2 Transmissions Between Your Web Browser and Our Servers
We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.
15.1.3 Storage of Your Personal Information
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.
15.2 Your Security Measures
For your own privacy protection; we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.
We also encourage you to be careful about who you give personal information to. We never email you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.
16. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We will only retain your personal information 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. If you would like to know more about our data retention policy, please ask us.
17. YOUR RIGHTS
17.1 Access to Your Personal Information
You have certain rights of access to your personal data under the Privacy Act 2020. You may request us to tell you whether we are processing personal information about you, to tell you what personal information we are processing and for what purposes, and to provide you with a copy of your personal information that we hold. The law does allow us, in certain cases, to refuse your request, and we will advise you at the time if this is the case. If we refuse to provide you with access to information we hold about you, we will provide reasons for such refusal and inform you of any exceptions relied upon under the Privacy Act 2020 or other applicable laws.
17.2 Use Causing Substantial Distress or Damage
You may ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.
17.3 Use for Direct Marketing
You may ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you. To opt-out of receiving direct marketing from us please follow the instructions detailed at the bottom of all our email marketing communications or contact us by phone on 0800 568 769 number or email us at email@example.com.
17.4 Correction of Inaccuracies
You may ask us to correct any personal information about you that we hold and you may have certain rights under the applicable local laws for your personal information to be rectified, blocked, erased or destroyed. In some circumstances, we may refuse to your request (to the extent permitted by law).
You may claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.
17.6 Complaints to Applicable Authority
New Zealand privacy law is regulated by the Privacy Commissioner in New Zealand (www.privacy.org.nz). In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from the Privacy Commissioner. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.
We keep our privacy notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change. You can check the top of the document to see the latest version in force.
19. CONTACTING US