This Privacy Policy applies to all companies in Holmes Place Spain.

NAME: RSG GROUP ESPAÑA, S.L.U

CIF: B57223570

ADRESS: C/ Modesto Lafuente 84, 1ª Planta, 28.003 Madrid

Who is responsible for the treatment?

The person responsible for the treatment, pursuant to Article 4.7 of Regulation (EU) 2016/679, of data protection is: "the physical or legal person, public authority, service or another body which, alone or together with others, determines the purposes and means of treatment ..." All companies are handed over to the parent company. Why? Because the main company, RSG GROUP ESPAÑA, S.L.U. lends to the other companies what we call 'central services' which include customer management, human resources, procurement, tax and labour management, auditing, etc. under which it requires full knowledge of all information. If you have any kind of consultation, suggestion, comment or concern about how we use your personal information, you can send a mail to the Holmes Place Spain Group's Data Protection Delegate to the following email address: dataprotection_es@holmesplace.com.

Holmes Place Spain collects his personal data by different means and ways. Specifically:

- Information you give us: We collect the personal information that you provide us through the web or websites and/or applications (Apps), e-mail, mobile phone, in the various contracts that you can sign with us, when you fill in a form, or others. In these cases, the personal data that we normally collect are: name and surnames, domicile, mail and contact telephone, DNI, date of birth or age, gender, whether or not it is a partner of the club, banking data - when buying or hiring or being discharged as a partner

- and, in some cases, we collect interests or objectives by hiring us (e.g., losing weight, gaining muscle, etc.). Eventually, it is possible that for some of our services we ask you for health data.

- Information we collect from your visits on our websites: Another way we have to collect personal data is indirect. How? Using Cookies which allows us, in addition to being able to navigate our website and use its services and features, we also obtain information about the user's use of our website (most visited websites) but which gives us general patterns of usage - that is, without identifying individuals - and detecting possible errors on the web. We also collect data on the activities of users on our website and others in order to customize the advertising we offer (we collect statistical data without identifying the person because what we collect is statistics on the dissemination of our website; the number of times the content of our website has been shared on a social network; the number of times that content has been accessed from our website on social networks, etc.) and on the comments made on us (that is, we have tools that allow us to manage, from a single website, the comments made by all netizens on all websites and/or social networks where we have a presence).

In any case, the information we collect is as follows:

a) Personal data that the user will provide us actively and voluntarily through forms, messages, comments and analogous communications that will make us reach us. In these cases we will get user identification data (names, surnames, email, telephone number and that information sent in the message by the user.)

b) Information that the user sends us automatically when navigating our website, such as the Internet Protocol (IP) address of the device that he is using, the navigation program that he is using, his operating system, the date and time of access, the Internet address of the website he accessed and also information about how he uses our website. This information is collected through the use of cookies. The Holmes Place Business Group Cookies Policy can locate it in the following link: Cookies policy.

-         Social networks: In view of the increased use of social networks, it is also a means of contact with users. The user is required to consider that any information he publishes in the Holmes Place Business Group profiles will become public information and will be accessible and available to users or visitors on these social networks and to the general public. What do you mean? Any person in the world, regardless of country, will be able to have access to the information you publish, as well as to your username, image and all that public information of your profile on the social network.

Therefore, the Holmes Place Business Group does not make itself responsible for the personal information that the user publishes on social media.Personal data that users/as contribute to social networks where the Holmes Place Enterprise Group has a presence will be treated for:

1. Interact with users.

2. Manage or process your applications, requirements or queries either by the Holmes Place Business Group.

3. It is also possible that we will deal with your data when competitions, promotions, competitions and/or any other similar activity are organised and you enter or note them.

4. Control and moderate the user's use in the Holmes Place Business Group profiles.

Basically, the objective of the Holmes Place Business Group on social networks is to know what is thought of the services, activities, offers, promotions and products it offers; to know the preferences and needs (which services people like, which people talk about more, etc.) of users and to publish information from the Holmes Place España Enterprise Group on corporate, commercial, advertising and/or promotional character, as well as the events and activities it organises. In any case, the information that we can get from users on the social networks where we have a presence is available online and to the public.

It should also be borne in mind that these social networks certainly have their own privacy policies explaining who they deal with, how they deal with and for what purposes their users' personal information. For this reason, the Holmes Place Business Group recommends that you read these privacy policies before using these social networks in order to ensure that you agree with the way in which you are collecting, dealing and sharing your personal information. The Holmes Place Business Group cannot be held responsible for the treatment of their personal data by these social networks.

The Holmes Place España Business Group currently has a presence on social media: Facebook; Instagram and Twitter.

-         Mobile phone and other electronic devices: The Holmes Place Group offers the public an application (APP) in which the user can register in order to be able to consult the hours of the activities and manage their favourite classes - those he has marked - the news and events organised by the Holmes Place Spain Group, its inbox and health, spa and wellness articles.

In applications we can find ourselves in three situations:

o  Or not to be a partner and schedule a visit to the club that you prefer, and in this case we will ask for the following information: first name and last name, country of residence, club chosen, your preferences (which you want to achieve by pointing to the Club), your post and contact telephone.

o  Or not to be a partner and wish to register that, in order to do so, it must first be a partner of one of the clubs in the Holmes Place Enterprise Group because it is requested: the country where your club is located; your DNI and the contact post that you have given the club in its registration.

o  Or Being a partner and already being registered that in this case the application can be accessed by using the contact email provided to the club in the registration as a partner and the chosen password.

In any of the above cases, by making use of the Holmes Place Spain Group application, it has a geolocation tool that has the main purpose of knowing its location to indicate or show the club closest to its location.

Therefore, having the mobile device's geolocation function enabled allows it to benefit from this functionality and if not, that is, if it doesn't have geolocation enabled, we will warn you (you can see how a message emerges in the center of the screen when you access the application) and ask you permission beforehand. The Holmes Place Group does not use geolocation functionality to facilitate its location to third parties, except for legal imperatives. Most mobile devices allow the user to disable geolocation features. If we have doubts about how to do this, we encourage you to contact your mobile service operator and/or the manufacturer of your mobile device.

In addition, it will be able to contact us through the application which, in this case, we will ask for your name and surnames, your mobile phone and contact e-mail, the club chosen and the service on which your communication is based, as well as the message that you want to send us.

-         Third party data: The Holmes Place Business Group does not accept third party data being communicated to it. However, if it does, the user declares that he has the express and informed consent of these third parties, and has informed him of all the extremes of this Privacy Policy. Therefore, the user exempts Holmes Place from any responsibility. Likewise, the Holmes Place Business Group will be able to carry out any actions it believes appropriate to check this.

-         Age Minors

All contact forms and/or higher, as well as the content of the website and/or apps offered by Holmes Place Group are not aimed at under 16. Therefore, in the case of children under 16 years of age, it must be their parents, their guardians and/or guardians who authorise the treatment of children's data.

The Holmes Place Business Group will ensure, in a reasonable way, that no less than 16 years of age is allowed to access services, products, promotions, offers, competitions, etc. which they offer taking into account the technology available. For this reason, it should be borne in mind that the Holmes Place Enterprise Group will be able to contact the user in order to check the actual age and verify that it matches the one communicated in the corresponding form and/or contract.

If we get underage information by some mistake, we will remove it as quickly as possible.

-         Use MyVitale and MyWellness platforms: It is possible that, from our services, you can benefit from the use of the MyVitale and MyWellness applications. Specifically:

o  MyVitale is an application that offers an intelligent training system with which Holmes Place Corporation has a contract formalized as the manager of the treatment. However, their use is voluntary and how the user interacts with this application and our gymnasium as well (because, for example, if he so wishes, their results can be put on our screens in order to 'comparate' with other users).

o  MyWellness is an application that allows the user to set themselves training, fitness and healthy life objectives and monitor their physical activity in order to meet previously set targets. The Holmes Place Business Group has a contract to deal with the owner of this application. However, their use is voluntary and how the user interacts with this application and our gymnasium as well (because, for example, if he so wishes, their results can be put on our screens in order to 'compare' with other users).

In relation to these applications, what should the interested party know?

1. The Responsible for the Treatment of its data is RSG GROUP ESPAÑA, S.L.U, and those responsible for the treatment are the owners of these applications: INTELLIGENT SYSTEM VITALE, S.L. and TECHNOGYM, S.p.A.
2. The data these applications know about the user are: first name and last name, email and telephone, date of birth, age, sex and physical characteristics, as well as health data and biometric data. All this data is collected by user consent to download the application, register and use it. In addition, if you hire certain services from the Holmes Place Enterprise Group, you may collect health data and the results of the tests carried out on the interested party may be transmitted via the MyVitale app if you have a registered account and that is what you want.
3. Why use this data? As a general rule, the Holmes Place Business Group does not deal with the data that the user transfers to these applications, except when the services that they do have to access are provided under (e.g., physiotherapy or training personnel).
4. the categories of recipients of their data will be RSG GROUP ESPAÑA, S.L.U. and the corresponding application manager. There is no provision for international data transfers.
5. the data contained in this application will be kept as long as you are registered in them and then some of them may be retained in order to be able to face any liability arising from the use of these applications by users.
6. Either the rights to data protection are: access to personal data relating to the interested party; and thus correction or limitation of its treatment, or opposition to treatment, as well as the right to data portability. It also has the right not to be subject to automated decisions (including profiling) that affect it legally or significantly in a similar way and the right to withdraw its consent when it wishes, without affecting the legal treatment prior to its withdrawal and the eventual contract between us. You can exercise all these rights by sending a mail to our Data Protection Delegate dataprotection_es@holmesplace.com and/or using the enabled link if applicable in the application.
7. Similarly, it has the right to come to the Spanish Data Protection Agency (www.aegpd.es) if it believes that the company has not respected its rights.
8. the data requested in the applications are essential to be able to register and use them. However, this is not an obligation.
9. Finally, it is reported that the communicated data will not be used to make automated decisions (including profiling) that affect it legally or significantly in a similar way.
10. Manage and know your usage preferences. This treatment does not collect personal data you have not provided previously, but only records from your activity in our platforms for statistical purposes and to be able to offer a better service. This treatment is based on our contractual relationship.

1. Manage the queries, doubts, suggestions and complaints that make us both through the web, e-mail, and through any other communication media that connects us with the user. 2. Security management of the Holmes Place Enterprise Group's Sites, People and Goods. In club facilities you can see the ID signal for the use of video surveillance cameras. This treatment is legitimate in the legitimate interest of any company to ensure the safety of its enclosures, as well as the goods it contains and the people who move. 3. Celebrate and manage our contractual relationship in case of a partner. This treatment includes: 3.1. The management of the registration procedure as a partner; contact you by mail or telephone, after registration has been completed, to finish explaining the steps to be taken (high online), send you all the documentation you must know and/or have in order to be able to come to the club and manage the payment of your registration. This treatment is legitimate in our contractual relationship; 3.2. Schedule the welcome sessions, as well as those offered by the club and you want to go (customer loyalty program), track from your high until you go to the selected club and conduct satisfaction surveys. This treatment is legitimate in our legitimate interest to want to keep our clientele. 3.3. To address all the consultations, suggestions, doubts and complaints that may arise in our contractual relationship. This treatment is legitimate in your consent, in contact with us. . Perform the appropriate procedures so that, if the application is downloaded, it can be identified and accessed as a partner (as well as use all the functionality that it offers). This treatment is based on our contractual relationship (in relation to being able to use your data so that you can identify when the application is downloaded), but then everything you do in the application is based on your consent and also on our contractual relationship because only partners can use the application). 3.5. Make it possible that as a partner they can already participate in all those events, competitions, promotions, offers, activities and services that are only offered to the partner. 4. Contact the client during the contractual relationship (for example, if a class is suspended, its service is delayed, etc.). This treatment is based on our contractual relationship. 5. Management of accident insurance at the facility. This treatment is based on the consent of the partner. Manage his registration in competitions, promotions and/or offers organized by Holmes Place Business Group and, if necessary, submit the prize. This treatment is based on their consent when enrolled. 7. Managing and processing the services it contracts with the Holmes Place Business Group (e.g., physiotherapy services, spa, etc.) This treatment is based on our contractual relationship and can lead to us collecting health data from the interested party. This treatment includes: 7.1. The management of the contract service; send him all the documentation he needs to know and/or have in order to be able to come to the club and manage the payment of his/her high. This treatment is legitimate in our contractual relationship; 7.2. Schedule the welcome sessions, as well as those offered by the club and you want to go (customer loyalty program), track from the recruitment of the service to the selected club and conduct satisfaction surveys. This treatment is legitimate in our legitimate interest to want to keep our clientele. 7.3. To address all the consultations, suggestions, doubts and complaints that may arise in our contractual relationship. This treatment is legitimate in your consent, in contact with us. 7.4. Perform the appropriate procedures so that, if the application is downloaded, it can be identified and accessed as a partner (as well as use all the functionality that it offers). This treatment is based on our contractual relationship (in relation to being able to use your data so that you can identify when the application is downloaded), but then everything you do in the application is based on your consent and also on our contractual relationship because only partners can use the application). 7.5. Make it possible that as a partner they can already participate in all those events, competitions, promotions, offers, activities and services that are only offered to the partner. 8. Celebrate and manage our contractual relationship in case you request an invitation to go to the club and/or to a specific class or activity offering a club from the Holmes Place Business Group. This treatment includes: 8.1. Send your invitation to the club and/or to the chosen class or activity; contact you by mail or telephone, after registration, to finish explaining the steps to follow, send you all the documentation you must know and/or have to be able to come to the club and manage the payment (because there are sometimes certain activities that have a price). This treatment is based on our contractual relationship. 8.2. Monitor from the request to the selected club and perform satisfaction surveys. This treatment is legitimate in our legitimate interest to wish to faithfulise the person as a client. 8.3. To address any consultations, suggestions, doubts and complaints that may arise. This treatment is legitimate in your consent, in contact with us. 9. Manage user registration on the web and/or in the application, as well as their personal area. This treatment is based on their consent when enrolled. 10. Celebrate and manage our contractual relationship in relation to hop. This treatment includes: 10.1. Manage your registration and client area (name, surnames, email and contact phone, as well as the password after registration). This treatment is based on their consent when enrolled. 10.2. The payment management of the acquired. This treatment is based on our contractual relationship, on purchasing a product, service or activity in the shop. 11. The sending of commercial communications in relation to products already acquired. This treatment is based on our legitimate interest based on Article 21.2 LSSI. You can unsubscribe at any time when you send this type of communication by clicking on the “unsubscribe” link or by typing a mail into our Data Protection Delegate: dataprotection_es@holmesplace.com. 12. The sending of our Newsletter and the sending of commercial communications by third-party companies in the entertainment, welfare, sport, by mail and/or SMS sectors. These treatments are based on their consent.It can be unsubscribed at any time when sending this type of communication by clicking on the 'unsubscribe' link or by writing a mail to our Data Protection delegate: dataprotection_es@holmesplace.com. 13. Compliance with our legal obligations. This treatment is based on the duty of all traders to comply with all those legal obligations imposed on them by the legislation (e.g. tax, tax, accounting, data protection, etc.). In addition, having to comply with legal obligations may mean that we retain certain data from them once they exercise their right to delete the data during the time in which they may be responsible to us so that we can defend ourselves against any complaints, complaints and/or complaints and/or make them. Similarly, we may also retain your data in order to ensure that we do not send you commercial communications when you have asked not to continue receiving them. 14. Perform statistical analyses and market studies in order to improve our decision-making. This treatment is based on our legitimate interest in any company to improve the services and products it offers. 15. Develop commercial profiles. Like every company, its customers’ ‘commercial profiles’ are created in order to evaluate our customers’ tastes and preferences. How do we do that? On the basis of the information you provide, as well as the purchases made. In addition, we use cookies under which we get global data (i.e. we don't identify people) in order to know what they like most, that websites are visited more, how many times users access a link, etc. This allows us to customize the advertising campaigns we do. In any case, these profiles do not involve automated decision-making (including profiling) that affects them legally or significantly in a similar way. This treatment is based on our legitimate interest to maximise all the advertising campaigns we do. 16. Managing our website and/or applications, as well as using them: ensuring proper web operation and/or application; improving user experience; detecting and correcting errors; detecting how long it takes to load our web, etc. How do we do that? By using cookies you can get more information in our Cookies Policy. These treatments are based on our legitimate interest in wanting to optimise the services we offer, as well as their consent to navigate by accepting the use of cookies. 17. Prevention of fraud. This treatment is legitimate in our legitimate interest to ensure the safety of our clubs. 18. Staff selection management. This treatment is legitimate in your consent by giving us your data, CV and other similar information. 19. Use your image for commercial and/or advertising purposes. This treatment is based on their consent. 20. Perform satisfaction surveys after our contract partner-business relationship is over. This treatment is based on their consent.

Your personal data will be communicated, depending on:

- The Holmes Place Business Group companies for internal administrative purposes and/or for the previously stated purposes (although in certain cases their consent is requested for this)

- Services agencies that allow us to comply with all the above-mentioned purposes (e.g. software providers, managers, auditors, security services, etc.). These providers only have access to the data needed to be able to provide the service we have hired and always under our instructions under a contract as the handling officer.

- The third parties needed to comply with previous purposes (banks and public administrations) in order to bill and fulfil our legal obligations. These providers only have access to the data needed to be able to comply with the purpose for which this loan is made.

- Public administrations, supervisory authorities, competent national and/or European authorities; judicial authorities; judicial bodies and/or public prosecutors, in cases provided for by law.

By accepting:

• our accident insurance company inside the club.
• the instant messaging app WhatsApp (from the company WhatsApp, inc.).
• if you agree to the treatment of your image, you must know that it will be distributed, broadcast, reproduced and communicated to the public by any means, both in paper and in electronic format without time or geographical limits. To promote the activities of Holmes Place Group companies.
• If you participate in a contest, promotion or offer, the name of the winner may be public Your data will not be communicated to third parties outside the Holmes Place Enterprise Group, only those service providers who need it to develop the service we are employed in. Not all of the purposes described imply a transfer of data. Because the data is collected directly by each of the companies in the Holmes Place Business Group (because each of them owns certain clubs). However, the parent company, HP Health Clubs Iberia, lends all companies in the group central services and thus knows the data of customers and suppliers, as well as staff and personal potential.

In principle, all the data we collect from you are kept in Europe. However, personal data may be processed or stored in countries outside the European Economic Area (EEA), depending on where our service providers are located. In this case, data will only be transferred outside the EEA if it offers guarantees comparable to those granted and required by the European Union. It should be borne in mind that some of our service providers outside the EEA are Facebook, Inc. or Google, LLC (cookies) and will be able to access their personal data. These companies are considered safe because they are part of the Privacy Shield, which makes them consider safe data protection companies in accordance with the European Commission's Executive Decision of 12 July 2016/1250. It is also remembered that if you agree to the processing of your data to use the Instant Messaging app WhatsApp. This application is owned by a company, WhatsApp Inc. The interested party will be able to find more information about this in: - European Commission Adjunct Decision No. 2016/1250, of 12 July: https://www.boe.es/doue/2016/207/l001-00112.pdf - Privacy Shield of WhatsApp: https://www.privacyshield.gov/participant?id=a2zt000000tsnwaag

Third-party websites accessible from our website are under the responsibility of those third parties. Therefore, the Holmes Place Business Group has nothing to do with them, nor with their privacy policies. That is why we encourage the interested party to report on third-party websites in order to ensure that they agree with their content.

The personal data provided will be retained for the purpose for which they were collected, as well as for the enforcement of our legal obligations and for the defence of our interests (for example, if we are to defend ourselves in the courts) or for statistical or historical purposes. The criteria we use are as follows: - The data we collect when you hire us (membership, invitation, purchases, etc.) will be retained as long as our contractual relationship lasts. - The data we collect when contacting us (in case of consultations, suggestions, requests etc) will be retained as long as necessary to be able to process its communication. - The data we collect when an account is created on the web and/or in applications will be kept for as long as our contractual relationship lasts (if it is a partner) or if it is not, until you ask us to delete it and/or after a period of inactivity time (i.e. without interacting with us) that we will automatically delete its account. - Treatments of your data based on your consent will be retained as long as your consent is retained and/or after a period of inactivity (i.e. without interacting with us) which, in this case, we will automatically delete your account. - Personal data relating to employment candidates will be retained for one year unless you said otherwise at the time of their collection. Then the candidate must know that, if he wants us to take this into account for future processes, he will have to send us his CV and any similar information he wants to let us know. - In relation to the images captured by video surveillance cameras, they will be retained for a maximum of 1 month. - The data collected using cookies will be retained for the time needed to meet its purpose. The retention period will be that marked in our Cookies Policy. All these data may subsequently be kept duly blocked during the period of limitation of any liability that may arise from this contractual relationship.

- The right to be informed: The interested party has the right to know, in a clear, comprehensible and transparent way, how, for what, who and how far their personal data are handled, and how much rights they have in connection with the processing of their data. - Access Law: The interested party is entitled to know whether personal data concerning it is being processed and, in this case, to know the purposes of treatment, the categories of data known, the recipients of their data and the rights which may concern it, among others. - Corrective law: The interested party has the right to correct data that is inaccurate and/or to complete those incomplete. - Data deletion right (right to forget): In those cases laid down in the legislation, the interested person is entitled to have his personal data deleted or deleted. It should also be mentioned that, even if this right is exercised, it is possible that we will retain them, properly blocked, for legal reasons (in order to be able to defend ourselves against eventuality, complaint, complaint and/or complaint). - Right to treatment limitation: In those cases in the legislation, the interested party may request that their data be limited (which will prevent us from continuing to treat or use them) but we can keep them so that we can formulate, exercise and/or defend ourselves against any complaints. - Data portability right: The interested person has the right to move, copy and/or transfer his personal data from our database to another one that tells us. However, this right is only possible when the data is based on the execution of a contract or on its consent and the treatment is done by automated means. - Right to opposition to treatment: The interested party has the right to oppose the processing of its data when it is based on the satisfaction of legitimate interests, including profiling and direct marketing. - Right to withdraw your consent: The interested person has the right to withdraw their prior consent for those treatments based on their consent. In any case, withdrawing their consent will not affect the request for treatment based on prior consent prior to their withdrawal. In any case, withdrawing your consent will not affect the execution of the contract that may exist between us. All these rights can be exercised by sending a mail to our Data Protection Delegate: dataprotection_es@holmesplace.com He also has the following right: - Right to file a complaint to a control authority: The interested party has the right to claim before the Spanish Data Protection Agency (www.aepd.es) whether it appreciates that the Holmes Place Business Group does not comply with the current legality and/or has violated its rights in relation to data protection.

We would ask you to inform us immediately of any changes in your data so that the information contained in our files is always up-to-date and does not contain errors. Also, accepting our Privacy Policy, the person concerned/or declares that the information and data he has provided are accurate and verace. In the Holmes Place Enterprises Group we ensure the safety and confidentiality of their data, and that is why we adopt safety measures which make it difficult to lose, misuse or accessible to unauthorized persons. However, we will not be responsible for the information that you choose to share with other users. We are committed to acting quickly and responsibly if the security of their data is affected and if relevant, we are committed to reporting it.

People involved in the processing of data concerning physical persons and access, directly or indirectly, to the files and data treated by Holmes Place, will always observe and respect the secrecy of the personal data they know in the development of the activity. For this reason, Holmes Place has performed training and sent instructions to all staff in connection with the processing of data. This obligation affects both internal and external staff and our suppliers.

When using our services, you can share information about services on social networks such as Facebook, Twiteer or Instagram, via an implemented social plug-in. If you choose to share information using a social plug-in your browser will transfer the following data to the social network: - Date and time of visit; - The Internet address or URL for the address you are temporarily visiting; - Your IP address; - The browser you are using; - The operating system you are using; - Your username and password and if you are a registered user of your social network, name and surname; - The information this specific plug-in used for. You must bear in mind that we have no impact on the information that the social network collects through the use of plug-ins. In addition, with regard to this information, we refer to the terms and conditions of the relevant social network. We encourage you to keep you informed of the purpose and scope of the information gathered through social plug-in. If you wish you can block social plug-in in browser settings.

The Holmes Place Business Group has implemented the necessary security measures to ensure effective use and processing of data, protecting the privacy, privacy and confidentiality of these data in accordance with the requirements laid down in existing legislation, using the means necessary to prevent the alteration, loss, unauthorized access or processing of their data, according to the state of the technology at any time, as well as the scope of control of the Holmes Place Enterprise Group. In addition, we also ensure that our staff are trained and instructed in the area of data protection. In addition, in order to ensure security of their data, commercial transactions are carried out in a secure server environment under SSL protocol (Secure Socket Layer).

This Privacy Policy was updated in April 2019. The Holmes Place Business Group reserves the right to partially or completely modify the content of this Privacy Policy, or update its content, in order to bring it into line with the regulatory changes and reality of the Holmes Place Business Group. The Holmes Place Business Group will publish any edits or updates on this website. We therefore encourage the user to access the Privacy Policy regularly in order to be kept informed.