Privacy Policy

At Billinghurst Institute, we respect your privacy and are committed to protecting it. Every company has a privacy policy, but when it comes right down to it, we want you to understand how we protect your privacy and to know what data we collect and how we use it. So let’s get to it.

Effective Date: November 13, 2023

Your privacy is very important to Billinghurst.Institute. The following Privacy Policy explains how we collect, use and safeguard the information you provide to us through the Billinghurst.Institute web site and its related features and functions.

Billinghurst Institute LLC (“Company” or “we”), is the licensee and operator of Billinghurst.Institute, and its web sites and associated computer functions (hereafter the “Site”), is committed to respecting and safeguarding your privacy online, as set forth in this Privacy Policy. This Privacy Policy sets forth the policies and practices of the Company with respect to information and other data that is received or gathered regarding visitors to, and members, subscribers and other users of, the Site and services provided by or related to the Site. The use of the terms “visitor”, “member”, “subscriber” and “Site user” shall, depending on your status shall mean and otherwise refer to you. The term “Third Party Program Participants” shall mean merchants, advertisers, promoters, content providers and others that the Company contracts with to provide goods and services via programs and Offers (as that term is defined below) available to Site users.

THIS DOCUMENT CONTAINS FOURTEEN (14) NUMBERED PARAGRAPHS. BEFORE YOU BEGIN OR CONTINUE TO USE THE SITE, OR ANY SERVICES OR FUNCTIONALITY PROVIDED BY OR THROUGH THE SITE, PLEASE CAREFULLY READ THIS PRIVACY POLICY. THIS PRIVACY POLICY CONTAINS IMPORTANT INFORMATION. IT IS ALSO VERY IMPORTANT THAT YOU FULLY UNDERSTAND OUR POLICY BECAUSE BY YOUR USE OR CONTINUED USE OF THIS SITE OR ANY OF ITS RELATED SERVICES YOU WILL BE EXPRESSLY SIGNIFYING THAT YOU AGREE TO THIS POLICY IN ITS ENTIRETY AND THAT YOU AGREE TO THE COLLECTION AND USE OF INFORMATION THAT YOU SUPPLY OR THAT IS COLLECTED ABOUT YOU, INCLUDING PERSONAL INFORMATION, AS DETAILED IN THIS POLICY STATEMENT.

ONLY ADULTS ARE AUTHORIZED TO USE THIS SITE. AUTHORIZED ACCESS AND USE OF THE SITE, ITS DATABASES AND FUNCTIONALITY IS LIMITED TO PERSONS OVER THE AGE OF EIGHTEEN YEARS, AND SUCH ACCESS AND USE IS LIMITED BY OUR TERMS AND CONDITIONS. THE COMPANY DOES NOT KNOWINGLY SEEK OR COLLECT ANY PERSONAL INFORMATION OR OTHER DATA FROM ANY PERSONS UNDER THE AGE OF EIGHTEEN YEARS.

IF YOU DO NOT UNDERSTAND OR DO NOT EXPRESSLY AGREE WITH ALL OF THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS AND CONDITIONS YOU SHOULD NOT USE THIS SITE OR THE SERVICES OFFERED OR OTHERWISE PROVIDED BY OR THROUGH THIS SITE.

Information Security

We are dedicated to the protection of Site user’s information. To prevent unauthorized access to information provided to us, the Company uses a number of generally accepted industry standard procedures designed to effectively safeguard the confidentiality of your personal information. These procedures include secure server location, controlled access to data and equipment, robust redundant firewall software, network monitoring, adaptive analysis of network traffic to track and prevent attempted network intrusions and other network abuse and appropriate employee training in the area of data security. We shall continue to take reasonable steps to provide effective data protection at all times, however, because no security technology can provide invulnerability to information compromise, the Company cannot, and does not, guarantee the security of any information that you transmit to us or to any third party affiliated with the Site.

Visitor, Subscriber, Member and User Information

When you visit or use this Site, including, for example, when you click on any of our links, we will collect and store in one or more of our databases, one or more of the following types of information (“Data”): your IP address (the domain name or other locator indicating your access to Internet); the IP address of the Web site from which you linked to our site operating system; browser data; email address data; the date and time you access our Site and its functions, and any other accessible online user, biometric or device information. We will often collect Data at several points throughout the Site, its links and through related functionality.

We use Data to measure the number of visitors to the different sections of our Site, to help us make our site more useful to visitors, to measure the amount of traffic generated through our affiliate network, to generate usage statistics, to ensure email reaches intended destinations, to generate special offers and advertisements which we may present to you, to provide our marketing partners, affiliates, licensees, purchasers and successors in interest with accurate Data and to prevent fraud.

Sometimes, we will ask you to provide, on a strictly optional basis, “Optional Information,” such as your name, username, address, zip code, telephone number, credit card data, or other personal information, such as other identifiers that permits physical or online contacting of you. For example, such information may be requested, on an optional basis, for participation in special promotions or other Offers (See Paragraph 7 below).

The only personally-identifying information we collect and store about you is the information you, voluntarily choose to provide to us, such as your name, e-mail address, address, zip code, telephone number, etc., in response to a specific prompt that requires you to initially enter the information. In addition, we, our agents, affiliates, Third Party Program Participants and others may ask you to voluntarily provide additional personal information for billing, shipping and other similar purposes.

When a visitor, member, subscriber, or other Site user, requests web pages from the Site’s server, clicks on banners or other links or otherwise uses the Site’s services or other functionalities, we or our agents may automatically collect some information or data about the user and the user’s Site use, including the IP address from which the Site is being accessed, the pages or links that were requested, the special preferences or requests of the user and cookie information received from the computer of the user. You agree that all such information and other Data may be collected and used by the Site and its agents.

When any Site user signs-on as a member or subscriber of this Site or related services, that person will be required to provide certain personal as well as demographic information. Such Optional Information, may include, but is not necessarily limited to, the subscriber’s name, address, birthday, e-mail address, gender, marital status, occupation, education, credit card number and expiration date of the credit card, username and password, and special interests or affiliations. This Site, the Company and its agents, may collect any and all such Optional Information and include it in its databases with Data and other information.

If a visitor, member, subscriber or other Site user sends any personal communication or correspondence, by any means, to the Site, the Company or any of its employees, agents or representatives, we may collect, in databases and otherwise, and use, any and all such information and other Data regarding that communication, consistent with this privacy policy.

Cookies

We use cookies for your convenience. For example, we use session cookies to make it easier for you to navigate and otherwise use our Site. Cookies are small pieces of data that are stored by a user’s Web browser on the user’s hard drive. Cookies can be used to “remember” what information a user accesses on one Web page to simplify subsequent interactions with that Web site by the same user or to use the information to streamline the user’s transactions on related Web pages. This makes it easier for a user to move between and interact with Web pages and to complete commercial transactions over the Internet. The Site also uses cookies to store and sometimes track information to make your online experience easier and more personalized and for other purposes related to your use of the Site and related services. For example, because a cookie can be linked to information you have inputted or which has otherwise been collected, the need to repetitively enter certain information, such as your username or email address, can be eliminated. The use of cookies also assists us in acquiring important Site usage Data. Cookies can also assist us in tracking and targeting the interests, preferences and desires of our Site users to present the most appropriate messages, offers and other communications to our users, and to generally enhance their experience at our Site.

Currently, there are two general types of cookies commonly used in association with typical Web sites including our Site: “session” cookies and “persistent” cookies. A session or “session ID” cookie is functional only during the current “session” use of your browser, i.e. it ceases to function when you close you browser. A “persistent” cookie remains on your hard beyond the current browser session. You can remove persistent cookies by following directions provided in your Internet browser’s “Help” file. We use both session cookies and persistent cookies.

Also, some Site use rewards and other benefits tied to Site usage use session cookies to track your Site usage and give you proper credit. We also use persistent cookies to track the actions of our users to enhance the experience on our site, other web sites and to more effectively communicate Offers, promotional data and other useful information to you. At the present time, we intend to also adopt and use helpful future cookie technology, and similar types of technologies, as they become available. We may implement any and all such new technologies and similar improvements to Site functionality without notice.

We may also track special offers, promotions and other advertising delivered by us, and your responses to them, by using cookies. This helps us reduce the number of offers that might not be interesting to you. We also use cookies to help us credit persons who referred or introduced you to us.

The Site may also automatically collect traffic and click-through data as well as information regarding the online behavior of subscribers and other Site users by the use of cookies or other programming means. Any and all information about Site users collected by the Company, or its agents or affiliates via the Site or otherwise, through the use of cookies or other programming means may be freely included in our databases and used in a manner consistent with this Privacy Policy.

Some of our Third Party Program Participants, advertisers, agents and others use cookies on or in association with our Site. We have no access to or control over these cookies. We may also allow third-party service providers to deliver special offers or services to Site users and to control the use of their cookies on your computer. Since such providers may set , access and otherwise control their cookies on your computer, we urge you to consult their privacy policies as they pertain to use of their cookies and the data collected from such use.

Most major Web browsers are set up so that they will initially accept cookies, but you may modify your computers preferences to issue you an alert when a cookie is downloaded, or to disable the ability of third parties to download a cookie to you. If you choose to reject cookies, or disable your computer’s ability to receive or process them, there are areas of this Site, other related web sites and related services that may not function properly. For example, you may not be able to view or interact with parts of the Site or access some of the services or offers otherwise available on the Site. Also, if you disable or reject cookies, you may not be credited for actions required for certain gifts and other benefits, and therefore may not receive such benefits.

Clear GIFs (“Web Beacons” or “Pixels”)

Clear GIFs, otherwise known as “web beacons”or “single-pixel GIFs”, are very small web page graphics that contain a unique digital identifying means. They function like cookies, in that they are often used to track and measure online actions taken by web site users. In contrast to cookies, which are stored on a user’s computer hard drive, clear GIFs are embedded into the graphics, text or other components of Web pages, including pop up windows, or in other digital documents that can support them, like email messages. We may also use Web Beacons to optimize search engine functionality. Clear GIFs are nearly invisible and are often only the size of small dot, such as a period at the end of a sentence. Also, like cookies, Clear GIFs, help us and our Third Party Program Participants measure and improve Site efficiency and effectiveness. For example, we may use web beacon technology to access your personally identifiable information or compile aggregated statistics about overall Site usage.

Many of our Third Party Program Participants and advertisers also employ Clear GIFs on our Site and in related sites.

Log Files

The Company and Third Party Program Participants, through the functionality of the Site, related sites and related services, gather Data and other information regarding Site navigation and Site use from cookies, clear GIFs and other means and store such information in log files and other databases. This Data and similar information includes date and time recordation data, Internet protocol (IP) addresses, Internet service provider (ISP) data, referring or exit pages, your computer’s operating system and components, such as your browser type, and other data. While this information generally does not directly identify individual users, it does provide us with Data and other broad demographic information. We use this information for a number of purposes including Site usage analysis, analysis of Site navigation by users, determining and analyzing overall user preferences and user trends, Site administration, and general improvement and optimization of Site efficiency and effectiveness and user communications, including promotions to users. We may also provide third parties with some or all such information and other Data collected

Use of Personal Information and Disclaimer

We may request personal identification information from you (such as your name, street address, telephone number, credit card number, e-mail address, and/or any other identifier that permits the physical or online contacting of you) in connection with your use of, or participation in, membership registration for Billinghurst.Institute our contests, sweepstakes, games, surveys, forums, subscription registrations, content submissions, chats, bulletin boards, discussion groups, requests for suggestions, visitors’s requests for free products or services or additional information (including via email to us), and in connection with other activities, services or resources we make available on any of our sites. In all of these cases, we will collect personal identification information from you only if you voluntarily submit such information to us. If you do provide us with personal information for any of these activities, we may use it to conduct the activity and we may also use it for all other purposes set forth in this Privacy Policy, including, without limitation, we may use the information to verify identity, protect against fraud, update and service your account, target and personalize future Offers that we may display on or in association with the Site and in our communications with you. We will use your physical mailing address for fulfilling Offers you have accepted, to improve our ability to provide you with more accurate and appropriate marketing and for other communications with our Company.

If you provide the Company with Optional Information, we may also use such personal identification information for internal or external marketing and promotional purposes. For example, we may send you e-mails to introduce a product or service that we think might be of interest to the users of our Site. For us to obtain your permission to send you this information, we will give you an opportunity to “opt-in” at the time our request for your personal information is made. If you do “opt-in,” you may choose to “opt-out” at any time, even after you have provided personal information, by following the procedures set forth in this Privacy Policy. Please note, however, that under certain circumstances, if you initially do not choose to “opt-in,” or if you later “opt-out,” you may not be eligible for certain benefits for which a name, e-mail address, telephone number or other personal identification information may be required.

We will release any and all specific information about you or your account to comply with any valid legal inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if there is an attempted breach of the security of the Site, or a physical or property threat to you or others. We may also transfer user information, including personally identifiable information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate change.

Further, the information you enter when making a purchase or an online donation will be shared with payment processors, financial gateways, and your credit card company to authorize credit card payments. Such information may also be shared with necessary third parties solely for the purpose or carrying out the transactions. Please note that if you give out personal information online, for example, by including such information in story or other submissions, posting, or on one of our public forums such as a message board or chat room, folder, chat IM feature, all such information can be collected and used by third parties. The Company shall have no obligation to guarantee the security of such information provided by you as set forth above. All such disclosures of such information is at your own risk.

By your use or continued use of the Site and/or its services, you expressly agree that the Company, via the Site and otherwise may use any and all Data, Optional Information and all other information that it or its agents gather or collect directly or indirectly pertaining to you, including, without limitation, any personal information that has been provided by you, your computer or other device, or information provided by a third party, for any and all technical, administrative, research, development, customer assistance, age verification, marketing, promotion and advertising uses, for the transmission of communications of every kind, including, without limitation, email communications of every kind, for the sending of products, for fulfillment purposes, and for compliance with any and all terms and conditions. Furthermore, you agree that the Company may share, disclose, lease, license, sell and otherwise provide any and all of such information, including personal information to its affiliates, agents, assigns, successors in interest, licensees, clients, customers, Third Party Program Participants and other third parties who have been authorized or permitted to use the information by the Company, its successors, assigns and licensees.

By your use or continued use of the Site and/or its services, you agree that the Company is not responsible or liable for the use of any information that you or any other visitor, member, subscriber or other Site user may provide to any other person or entity, or that is gathered by any third-party, including, without limitation, any Third Party Program Participant, by any means. This Site does not control, monitor or endorse the information gathering practices or Privacy Policies of any third-party, and you acknowledge that such third-parties and their web sites may, and probably do, have privacy policies that are different from this Privacy Policy. Whenever applicable, you and all other visitors, members, subscribers and other Site users are strongly advised to read the Privacy Policy of any and all third-party web site providers that have one or more advertising banners, or links on the Site, or on the web site of any Third Party Program Provider, and of any entity that provides goods or services at, through or in direct or indirect association with the Site.

All Members, visitors and Users of this Site should consider any information provided to or collected by the Site as non-confidential, and consequently the Site assumes no liability or responsibility if any information relating to any Member, visitor or User is intercepted and/or used by an unintended recipient.

Offers, Special Promotions, Opinion Polls, Surveys, Contests, Special Events and Service Alert Emails

There may be occasions when a visitor, subscriber, member or other Site user will be presented with special offers either from the operators of the Site, their agents, affiliates or from other third-party offerors, that may include the presentation of one or more options for a Site user to consent to receive e-mail solicitations, communications, newsletters or commercial advertising, or to participate in other promotions or special events, including without limitation, contests, opinion polls or surveys (collectively referred to as “Offers”). Offers might be made by the Company, its agents, affiliates, Third Party Program Participants or other third-parties making such Offers. Site users may be asked to provide certain information in order to participate in such Offers. Information requested may include, without limitation, contact information (such as name and address) and demographic information (such as zip code, area code, age level, occupation, etc.). Participation in such special events and special offers is completely voluntary and Site users may elect whether or not to provide the requested information. Information collected will be used for the purposes of winner notification, prize awarding, monitoring and improving Site usage and user satisfaction, providing additional relevant offers, promotions and other communications to Site users via electronic mail and other means, and other purposes consistent with this Privacy Policy.

“OPT-IN” Acceptance of Offers. Some Offers may be presented to you with the option to express your preference by either clicking or entering “accept” (or alternatively, for example, “yes”) or “decline” (alternatively “no”) or “consent” or by indicating your preference regarding participation or non-participation by some other recordable means. By selecting accept, yes, consent, or some other affirmation of participation, you shall be deemed to agree that such action(s) shall constitute an “OPT-IN” to the Offer related to the action and that the you thereby agree and assent that your personal information, Data, Optional Information and other information in the Site’s databases may be disclosed to the Company, the Company’s affiliates, agents, Third Party Program Participants and other third-parties offerors.

“OPT-OUT” Rejection of Offers Otherwise Accepted. Some Offers may be presented with a pre-selected preference or choice. If you do not deselect the pre-selected preference of choice (i.e. “OPT-OUT” of the Offer) then the Site may transfer your personal information to the Company, its affiliates, agents, Third Party Program Participants, and any other third party making the Offer. If you deselect the pre-selected preference (i.e., reject the Offer) then no personal information relating to the Offer in the Site’s database may be disclosed to a third party offeror of that particular Offer with respect to that particular Offer. Nothing herein shall limit information collection or transfer that you have previously authorized or subsequently authorize, including, without limitation any authorization regarding the third party offeror with respect to another Offer.

The Company may also send new members, subscribers, visitors or other Site users a welcoming email and occasionally send information on products, services, and special deals from Third Party Program Participants, and other third parties. If you don’t want to receive such email or other email messages from us, please follow the directions for unsubscribing or “opting-out” contained in the email message you receive from us. We reserve the right to contact you, however, with non-commercial relationship and other advisory email messages, such as communications of changes or updates to our software, changes to our Terms and Conditions, changes to Offers you have accepted, changes to programs you have elected to participate in, notice of termination of any Offer, program or service or changes to this Privacy Policy.

We may provide you with links in our email communications. These links may include one or more special tracking codes, unique to you or some other identifying feature (such as geo-location). These codes assist us in formulating, selecting and distributing content, promotions, Offers, advertisements and other communications to you which are more appropriately targeted to your likely preferences. We may share this data in aggregate form or in individual form.

The Company and/or Third Party Program Participants may offer you participation in one or more “rewards” programs in which you can earn money or other benefits for participating in such programs. The Company and/or Third Party Program Participants may provide information collected from you as a result of your participation in such program(s) to the program sponsor to assist the sponsor in delivering entitled benefits to you and for other marketing, promotional and other purposes. If you participate in any of the Company’s own reward or incentive programs, we will track your activity using your email address or other identifying means and share your email address and other identifying means with affiliated reward sponsors, if any, and any third parties involved with fulfillment of the rewards or other benefits.

The Company does not currently provide a process to update or modify a Site user’s personally identifiable information. If you no longer desire to use one or more of our services, you must, as relevant, opt-out of our mailings, unsubscribe, cancel membership, remove Company, Third Party Program Participant and/or other third party distributed software from your computer, and/or discontinue the use of the Site and services. The Company may, in the future provide a process to update or modify a Site user’s personally identifiable information, and if so, the means of updating or modifying such information will be specified in an amended version of this Privacy Policy.

Revocation of Consent Procedure (Revocation “Opting-Out”)

The Site also offers to you a procedure for “Opting-Out” if you subsequently choose to revoke or withdraw any consent to accept or receive Offers. To revoke or withdraw a consent to accept or receive Offers, send an e-mail through our contact page and selecting “Technical problems or questions” clearly stating that you have revoked or withdrawn consent to receive any future Offers. You may also Opt-Out or terminate subscriptions or memberships by visiting our contact page and selecting “Technical problems or questions” with clear instructions of what you’re opting out of.

You may also choose to revoke or withdraw any consent to accept or receive Offers by engaging a link enabling you to do so, which may appear at the bottom of relevant email(s) sent to you by the Company or a third party. It’s important to realize doing do will immediately remove you from that specific interest or “list”. You may be subscribed to other interested or lists. To be removed from every list and blacklist your email, simply reply to any of our emails with the subject, “Blacklist me”. Please allow up to two business days to perform this request.

If you decide to cancel a subscription, membership or other Offer and later wish to resubscribe, rejoin or recommence receiving a previously cancelled Offer, you may not always be able or entitled to do so, and you many not be entitled to receive credit towards benefits offered by the Company or a third party. We reserve the right at all times to terminate or suspend any subscription, membership, Offer, service or account at any time with or without notice.

Third Party Program Participants and Others

We may send you offers on behalf of Third Party Program Participants. Acceptance of some Offers through the Site may require you to provide personal information to Third Party Program Participants. These Companies may also independently send you Offers. If you would like to opt-out or cancel any such Offers or prevent Third Party Program Participants from independently communicating with you, you will need to inform them separately pursuant to their process for doing so.

The Company shares aggregated demographic and Site navigation information, Data, Optional Information and other information with Third Party Program Participants, advertisers, analysts and others. We may also sell access to our mailing lists, including email lists, and other information to brokers and third party advertisers and we may transfer your information to such third parties. We may transfer some or all of your information to a purchaser of all or part of our Company or any successor in interest in the Company or the Site. We may also hire contractors or other third parties to perform any Company, Site or Site service function with or without notice to you. The Company and its agents may also aggregate demographic and other information about you and other Site users in databases and disclose, license or sell such information to Third Party Program Participants and other parties.

By your use or continued use of the Site or acceptance of any Offer associated with the Site, you expressly agree that this Privacy Policy, all Data, Optional Information and other information collected by the Company, its agents, affiliates, Third Party Program Participants and all other third parties associated with the Company or the Site, all contractual rights and all rights arising under the terms and conditions be freely and unconditionally transferred, assigned, sold, leased or licensed to any person or entity and that all Offers are subject to change and may be terminated by the Company or any third party initiating the Offer, with or without notice.

Disclosure

The Company will not disclose or use any of your personally identifiable information except to the extent set forth in this Privacy Policy, or under special circumstances, such as when we believe in good faith that the law requires it, or when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating the Site’s Terms and Conditions, defrauding the Company or any third party, including any Third Party Program Participant.

The Company will disclose your personal information, without notice, to a party unrelated to the Company if required to do so by law or in the good faith belief that such action is necessary to comply with the law, legal process served on the Company or a Third Party Program Participant, to protect the rights or property of the Company or a Third Party Program Participant, or in urgent circumstances to protect the personal safety of users of the Site or the public at large.

All unsolicited information provided to the Company or any affiliated party, including, without limitation, any Third Party Program Participant, entirely on the initiative of a person providing the information or that person’s agent, or any information which is provided independently of any request by the Company or its affiliates shall be deemed to be public information regarding which neither the Company nor any other person or entity has any duty to the information provider or any other person, and as such, the Company may use such unsolicited information in an unlimited manner.

Protection of Children

The Company and Third Party Program Participants do not publish any content or Offers on the Site that are targeted to children. We do not specifically collect information about children. The Company and Third Party Program Participants do not solicit and do not knowingly accept subscriptions, memberships, or acceptances of Offers from persons under the age of eighteen years. If minors have access to your computer or email, we ask that you take appropriate measures to prevent such minors from accessing or using the Site or any of our Company’s services as they are exclusively offered and restricted to, and only authorized for, adults over the age of eighteen years.

Access to Information; Correction of Erroneous Information.

If you would like to review personal information we have retained about you in our database, please send us an e-mail request for this information through our contact form and selecting “Technical problems or questions” . Please indicate in detail which information you wish to review. After you have reviewed the data, we will make reasonable efforts to correct such personal information about you that you state in writing is erroneous. To request such a correction, please send an e-mail through our contact form and selecting “Technical problems or questions”. You should be aware, however, that it is not always possible to completely remove or modify information in our databases and servers although we will always make reasonable efforts to do so upon your request. You acknowledge and agree that the Company has no obligation whatsoever to provide you with data about you that has been transferred to one or more third parties and Company is not obligated to take any actions with respect to the data in the databases of any third parties, whether or not such data is erroneous.

Scope of this Privacy Policy.

This privacy policy applies to your use of the Site and services owned or operated by the Company. This policy does not apply to your use of unaffiliated sites to which are only linked to the Sites.

Revisions to this Privacy Policy

The Company reserves the right, in its sole and absolute discretion, to revise, amend, modify or revoke this Privacy Policy at any time and in any manner. Changes to this Policy will be effective by posting revisions on the Site. In some circumstances you might be required to actively “accept” or “agree” to a new Privacy Policy or to new or modified provisions in the Privacy Policy in order to continue using the Site or services provided by the Company or Third Party Program Participants. Such assent or agreement to revisions to this Privacy Policy may be effectuated via an Opt-In or Opt-Out procedure (as those procedures are discussed above).