PRIVACY POLICY
Effective Date: May 26, 2015
To view and print our full Privacy
Policy, click here. To view and print
our full Terms of Service, click here.
Overview
You
should read this entire Privacy Policy, but here is a partial list of some of
the key topics that are explored in greater detail throughout the Privacy
Policy. Any capitalized terms have
the meanings given to them where defined in the Privacy Policy.
•
We ask you for,
and use technology to detect, information about you. Some of this information is shared with
others as detailed below.
•
We give you the
right to opt-out of sharing of your Personal Information with third parties for
their direct marketing purposes, and in many cases will give you a choice even
if you have not opted out. This
complies with California Privacy Rights.
•
Portions of our
Service are designed for parents of pre-literate children and we do not intend
to collect personal information from Children. You can contact us if you think we have
inappropriately collected your child's personal information or otherwise
regarding children and our privacy practices, contact us in the following ways: Postal Mail: Genius
Brands International, Inc., 301 N. Canon Drive, Suite #305, Beverly Hills, CA
90210 ; By e-mail:
info@gnusbrands.com.
•
You consent to
our practices detailed in our Privacy Policy. Each time you use the Services, the
version of our Privacy Policy then posted will apply to that use (subject to Section
1), so you should check back each time you return for updates. To prospectively change your consent,
terminate your account, stop using the Service and uninstall any downloads and
apps.
Introduction
Welcome! You have arrived at www.EdisonSecretLab.com and/or are otherwise interacting with our Service (defined below) which is owned and operated by Genius Brands International, Inc. ("Genius Brands" or "we," "our" or "us"). This "Privacy Policy" governs your use of any online service location (e.g., web site or mobile app) that posts a link to this Privacy Policy (each a "Site") (including, without limitation, both mobile and online versions of our Site), and also applies to your use of interactive features, widgets, plug-ins, applications, content, downloads and/or other services that we own and control and make available through a Site, and/or that posts a link to this Privacy Policy (collectively, the "Service"), regardless of how you access or use them, whether via personal computers, mobile devices or otherwise, but does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below), and does not govern the data practices of third parties that may interact with our Service.
To the
extent we provide you notice on our Service of different or additional privacy
policies or practices (e.g., at the point of our collection), those additional
terms shall govern such data collection and use.
In
addition, please review the Service's Terms of Service, which
governs your use of the Service. By using our Service, you consent to our Privacy Policy and Terms
of Service and our collection, use and sharing of your information and data,
and other activities, as described below.
It is
important that you read and understand the entire Privacy Policy before using
the Service.
1. What
Information Does the Service Collect?
(a)
Information You Provide to Us
Personal
Information and Demographic Information. On the Service, we may ask you to
provide us with certain categories of information such as: (1) personally
identifiable information, which is information that identifies you personally,
such as your first and last name, e-mail address, home address, and credit card
information ("Personal Information");
and (2) demographic information ("Demographic
Information"). We may collect
this information through various forms and in various places on the Service,
including account registration forms, contact us forms, or when you otherwise
interact with the Service. To the
extent we combine Demographic Information with your Personal Information we
collect directly from you on the Service, we will treat the combined data as
Personal Information under this Privacy Policy.
(b) Information
We Collect or Store As You Access and Use the Service
In
addition to any Personal Information or other information that you choose to
submit to us via our Service, we and our third-party service providers may use
a variety of technologies that automatically (or passively) store or collect
certain information whenever you visit or interact with the Service ("Usage Information"). This Usage Information may be stored or
accessed using a variety of technologies that may be downloaded to your
personal computer, browser, laptop, tablet, mobile phone or other device (a "Device") whenever you visit or interact
with our Service. To the extent we
associate Usage Information with your Personal Information we collect directly
from you on the Service, we will treat it as Personal Information.
This Usage Information may include:
•
your IP address, UDID or other unique identifier ("Device Identifier"). A Device Identifier is a number that is
automatically assigned to your Device used to access the Service, and our
computers identify your Device by its Device Identifier;
•
your Device
functionality (including browser, operating system, hardware, mobile network
information);
•
the URL that
referred you to our Service;
•
the areas within
our Service that you visit and your activities there, including remembering you
and your preferences;
•
your Device
location;
•
your Device
characteristics; and
•
certain other Device data, including the time of day, among
other information.
We may use various methods and technologies to store
or collect Usage Information ("Tracking
Technologies"). Tracking
Technologies may set, change, alter or modify settings or configurations on
your Device. A few of the Tracking
Technologies include, without limitation, the following (and subsequent
technology and methods later developed):
Cookies. A cookie is a data file placed on a
Device when it is used to visit the Service. A Flash cookie (or locally shared
object) is a data file placed on a Device via the Adobe Flash plug-in that may be
built-in to or downloaded by you to your Device. HTML5 cookies can be
programmed through HTML5 local storage.
Unlike Flash cookies, HTML5 cookies do not require a plug-in. Regular cookies may generally be
disabled or removed by tools that are available as part of most commercial
browsers, and in some but not all instances can be blocked in the future by
selecting certain settings. Each
browser you use will need to be set separately and different browsers offer
different functionality and options in this regard. Also, these tools may not be effective
with regard to Flash cookies or HTML5 cookies. For information on disabling Flash
cookies, go to Adobe's web site www.adobe.com. Please
be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies
on your Device, some parts of our Service may not function properly, and that
when you revisit our Service your ability to limit cookies is subject to your
browser settings and limitations.
Web Beacons. Small graphic images or other web
programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs")
may be included in our Service's pages and messages. Web beacons may be invisible to you, but
any electronic image or other web programming code inserted into a page or
e-mail can act as a web beacon. Web
beacons or similar technologies may be used for a number of purposes,
including, without limitation, to count visitors to the Service, to monitor how
users navigate the Service, to count how many e-mails that were sent were
actually opened or to count how many particular articles or links were actually
viewed.
Embedded Scripts. An embedded script is programming code
that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto
your Device from our web server or a third party service provider, is active
only while you are connected to the Service, and is deactivated or deleted
thereafter.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a
web server to a specific version of a resource found at a URL. If the resource content at that URL ever
changes, a new and different ETag is assigned. Used in this manner ETags are a form of
Device Identifier. ETag tracking
may generate unique tracking values even where the consumer blocks HTTP, Flash,
and/or HTML5 cookies.
We may use
Tracking Technologies for a variety of purposes, including:
Strictly Necessary. We may use cookies or other Tracking
Technologies that we consider are strictly necessary to allow you to use and
access our Service, including cookies required to
prevent fraudulent activity, improve security or allow you to make use of
shopping‑cart functionality.
Performance‑Related. We may use cookies or other Tracking
Technologies that are useful in order to assess the performance of the Service, including as part of our analytic practices or otherwise to
improve the content, products or services offered through the Service.
Functionality‑Related. We may use cookies or other Tracking
Technologies that are required to offer you enhanced functionality when
accessing the Service, including identifying you when you
sign‑in to our Service or keeping track of our specified
preferences, including in terms of the presentation of content on our Service.
Targeting‑Related. We may use Tracking Technologies to
deliver content relevant to your interests on our Service and third‑party sites based on how you interact with
our content. This includes using
Tracking Technologies to understand the usefulness to you of the content that
has been delivered to you and to recommend other products and services to you.
There may be
other Tracking Technologies now and later devised and used by us in connection
with the Service. Further, third parties may use Tracking
Technologies with our Service. We may not control those Tracking
Technologies and we are not responsible for them. However, you consent to potentially
encountering third party Tracking Technologies in connection with use of our Service and accept that our statements under this Privacy Policy do
not apply to the Tracking Technologies or practices of such third parties. For more information on our vendors, and
their Tracking Technologies, see Section 3(b).
(c) Information
Third Parties Provide About You
We may receive information about you from your friends
and others that use the Service, such as when they submit content to us or post
on the Service. Additionally, we
may, from time to time, supplement the information we collect directly from you
on our Service with outside records from third parties for various purposes,
including to enhance our ability to serve you, to tailor our content to you and
to offer you opportunities that may be of interest to you. To the extent we combine information we
receive from those sources with your Personal Information we collect on the
Service, it will be treated as Personal Information and we will apply this
Privacy Policy to such combined information, unless we have disclosed
otherwise. In no other circumstances do our
statements under this Privacy Policy apply to information we receive about you
from third parties.
(d) Interactions with Third-Party Services
The Service may include functionality that allows
certain kinds of interactions between the Service and a third-party web site or
application. The use of this
functionality may involve the third-party operator providing certain
information, including Personal Information, to us. For example, you may elect to use third
party apps or plug-ins made available on our Services (e.g., Facebook and
Twitter). If we offer and you
choose to use this functionality via our Service, the third-party site or
application may send Personal Information about you to us. If so, we will then treat it as Personal
Information under this Privacy Policy, since we are collecting it as a result
of your accessing of and interaction on our Service. When you use third-party sites'
interfaces or links on the Service to facilitate your sending a communication
from the Service such as to facilitate emails, tweets or Facebook postings,
these third parties may retain any information used or provided in any such
communications or other activities and these third parties' practices are not
subject to our Privacy Policy.
Genius Brands may not control or have access to your communications
through these third parties.
Further, when you use third-party sites or services, you are using their
services and not our services and they, not we, are responsible for their
practices. You should review the
applicable third-party privacy policies before using such third-party tools on
our Service.
(e) Information
You Provide About a Third Party
You may send someone else a communication from the
Service, such as sending an invitation to a friend. If so, the information you provide
(names, e-mail addresses, etc.) is used to facilitate the communication and is
not used by us for any other marketing purpose unless we obtain consent from
that person or we explicitly say otherwise. Please be aware that when you use any
send-to-a-friend functionality on our Service, your contact information, name
or user name and message may be included in the communication sent to your
addressee(s). Some of these tools
may be third-party tools subject to third-party privacy policies as further
detailed in Section 1(d) and Section 5.
2. How
Do We Use the Information Collected?
Use of Information by Us. We may use your Personal Information,
Demographic Information or Usage Information that is subject to this Privacy
Policy: (1) to provide you with
information or services or process transactions that you have requested or
agreed to receive including to send you electronic newsletters, or to provide
you with special offers or promotional materials on behalf of us or third
parties; (2) to enable you to participate in a variety of the Service's
features such as online entry sweepstakes, contests or other promotions; (3) to
process your registration with the Service, including verifying your
information is active and valid; (4) to improve the Service or our services, to
customize your experience on the Service, or to serve you specific content that
is relevant to you; (5) to contact you with regard to your use of the Service
and, in our discretion, changes to the Service and/or Service's policies; (6)
for internal business purposes; and (7) for purposes disclosed at the time you
provide your information or as otherwise set forth in this Privacy Policy.
Please note that
information submitted to the Service via a "contact us" or other similar function
may not receive a response; we will not use that information so provided to
contact you for marketing purposes unrelated to your inquiry unless you agree
otherwise
3. How
and When Do We Share Information with Third Parties?
We may share
non-Personal Information, such as aggregated user statistics, with third
parties. We may share your Device
Identifiers with third parties along with data related to you and your
activities. We reserve the right to share your Personal Information that we have
collected directly from you on our Service with third parties for those third parties' direct marketing purposes unless you
have given us an opt out notice, which you can send to us by
e-mail to info@gnusbrands.com. However, we will often seek your
consent to such sharing at the time you provide your Personal Information even
if you have not opted out. If you
have opted out, giving consent will override the opt-out in that particular
instance. In addition, we may share the information we have collected
about you, including Personal Information, as disclosed at the time you
provide your information and as described below or otherwise in this Privacy
Policy. Genius Brands may disclose
your information as follows:
(a) When
You Request Information From or Provide Information to Third Parties. You
may be presented with an option on our Service to receive certain information
and/or marketing offers directly from third parties or to have us send certain
information to third parties or give them access to it. If you choose to do so, your Personal Information
and other information may be disclosed to such third parties, even if you have
previously opted out of such types of sharing generally, and all information
you disclose will be subject to the third-party privacy policies and practices
of such third parties. In addition,
third parties may store, collect or otherwise have access to your information
when you interact with their Tracking Technologies, content, tools apps or ads
on our Service or link to them from our Service, and by so interacting you
consent to such third party practices.
This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing
tools. It may also include ordering
or purchasing products from third parties through us where we indicate that the
third party rather than Genius Brands is the seller. We are not responsible for the privacy
policies and practices of such third parties and, therefore, you should review
such third-party privacy policies and practices of such third parties prior to
requesting information from or otherwise interacting with them.
(b) Third
Parties Providing Services on Our Behalf. We may use third-party vendors to
perform certain services on behalf of us or the Service, such as hosting the Service,
designing and/or operating the Service's features, tracking the Service's
activities and analytics, and enabling us to send you special offers or perform
other administrative services. We
may provide these vendors with access to user information, including Device
Identifiers and Personal Information, to carry out the services they are
performing for you or for us. Third-party analytics and other service providers may set
and access their own Tracking Technologies on your Device and they may otherwise
collect or have access to information about you, potentially including
Personal Information, about you. We
are not responsible for those third party technologies or activities arising
out of them. However, some may
offer you certain choices regarding their practices, and information we have
been informed of regarding such choices is available below. We
are not responsible for the effectiveness of or compliance with any third
parties' opt-out.
The following third parties that collect
information from you on the Service have given us notice that you may obtain
information on their policies and practices, and in some instances opt-out of
certain of their activities, as follows:
Party: Google
Service: Google
Analytics for Display Advertisers, Ads Preferences Manager, and Google
Analytics Opt-out Browser Add-on
For More Information:
http://support.google.com/analytics/bin/answer.py?hl=en&topic=2611283&answer=2700409
http://www.google.com/settings/ads/onweb/?hl=en&sig=ACi0TCg8VN3Fad5_pDOsAS8a4
https://tools.google.com/dlpage/gaoptout/
PLEASE NOTE: We are not responsible for third-party
policies or practices. We try to
keep this information current, and will add to and subtract from the chart
above as appropriate, but it is provided as a courtesy and may not be current
or accurate. Please contact the
applicable third parties regarding their privacy and data security policies and
practices.
(c) To
Protect the Rights of Genius Brands and our Users. To the fullest extent permitted by
applicable law, we may also disclose your information if we believe in good
faith that doing so is necessary or appropriate to: (i)
protect or defend the rights, safety or property of Genius Brands or third
parties (including through the enforcement of this Policy, our Terms of Service, and other applicable
agreements and policies); or (ii) comply with legal and regulatory obligations
(e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by
applicable law, we have complete discretion in electing to make or not make
such disclosures, and to contest or not contest requests for such disclosures,
all without notice to you.
(d) Affiliates
and Business Transfer. To the fullest extent permitted by
applicable law, we may share your information, including your Device
Identifiers and Personal Information, Demographic Information and Usage
Information with our parent, subsidiaries and affiliates ("Affiliates"). We also
reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the
Service or applicable database; or (ii) in connection with a merger,
consolidation, restructuring, the sale of substantially all of our interests
and/or assets or other corporate change, including, during the course of any
due diligence process.
(e) Co-Branded
Areas. Certain areas of the Service may be
provided to you in association with third parties ("Co-Branded Areas")
such as sponsors and may require you to disclose Personal Information to
them. Such Co-Branded Areas will
identify the third party and indicate if they have a privacy policy that
applies to their collection and use of you information. If you elect to register for products
and/or services, communicate with such third parties or download their content
or applications, at Co-Branded Areas, you may be providing your information to
both us and the third party. Further, if you sign-in to a
Co-Branded Area with a username and password obtained on the Service, your
Personal Information may be disclosed to the identified third parties for that
Co-Branded Area. We are not
responsible for such third party's data collection or practices and you should
look to such third party privacy policies for more information.
(f) Sweepstakes,
Contests and Promotions. We may offer sweepstakes,
contests, and other promotions (any, a "Promotion") through the Service
that may require registration. By
participating in a Promotion, you are agreeing to official rules that govern
that Promotion, which may contain specific requirements of you, including,
allowing the sponsor of the Promotion to use your name, voice and/or likeness
in advertising or marketing associated with the Promotion. If you choose to enter a Promotion,
Personal Information may be disclosed to third parties or the public in
connection with the administration of such Promotion, including, in connection
with winner selection, prize fulfillment, and as required by law or permitted
by the Promotion's official rules, such as on a winners list.
(g) Your
California Privacy Rights.
We may from time to time elect to share certain information about
you collected by us on the Service with third parties for those third parties'
direct marketing purposes if we think they may have products or services you
would find of interest. California
Civil Code Section 1798.83 permits California residents who have supplied
personal information to certain rights.
We comply with this law by giving all of our users (including California
residents) the ability to opt-out of our sharing of personal information (as
defined in that law) to third parties for their direct marketing purposes. You can make that request in the
following ways: Postal Mail: Genius Brands International, Inc., 301 N. Canon
Drive, Suite #305, Beverly Hills, CA 90210
; By e-mail: info@gnusbrands.com.
If you have made that request, you can change
it at any time, including on a case-by-case basis by opting in to certain
sharing opportunities.
4. What
About Information I Disclose Publicly Or To Others?
(a) User-Generated
Content and Public Information. The Service may permit you to submit
ideas, photographs, user profiles, writings, music, video, audio recordings,
computer graphics, pictures, data, questions, comments, suggestions or other
content, including Personal Information (collectively, "User Content"), such as on blogs and message boards. We or others may store, display,
reproduce, publish, distribute or otherwise use User Content online or offline
in any media or format (currently existing or hereafter developed) and may or
may not attribute it to you. Others
may have access to this User Content and may have the ability to share it with
third parties. Please think
carefully before deciding what information you share, including Personal
Information, in connection with your User Content. Please note that Genius Brands does not
control who will have access to the information that you choose to make public,
and cannot ensure that parties who have access to such publicly available
information will respect your privacy or keep it secure. We are not responsible for the privacy
or security of any information that you make publicly available on the Service
or what others do with information you share with them on the Service. We are not responsible for the accuracy,
use or misuse of any User Content that you disclose or receive from third
parties through the Service.
(b) Name
and Likeness. We may also publish your name, voice,
likeness and other Personal Information that is part of your User Content, and
we may use the content, or any portion of the content, for advertising, marketing,
publicity and promotional activities. For full terms and
conditions regarding User Content you submit to the Service, please review our Terms of Service.
5. Do Third-Party Content, Links To Third-Party
Sites, and/or Third-Party Apps Appear on the Service?
The Service may contain content that is supplied by a
third party, and those third parties may collect Usage Information and your
Device Identifier when pages from the Service are served to you. In addition, when you are on the Service
you may be directed to other services that are operated and controlled by third
parties that we do not control. We
are not responsible for the data collection and privacy practices employed by
any of these third parties or their services and they may be tracking you
across multiple sites and may be sharing the results of that tracking with us
and/or others. For example, if you
"click" on a link, the "click" may take you off the Service onto a different
site. These other sites may
associate their Tracking Technologies with you, independently collect data
about you, including Personal Information, and may or may not have their own
published privacy policies.
Third-party applications may also be available via the
Service. The owners of these
applications ("Third-Party Owners")
may collect Personal Information and other data from you and may have their own
policies and practices. We are not
responsible for how Third-Party Owners or their applications collect or use
your information and they may be tracking you across multiple sites and may be
sharing the results of that tracking with us and/or others. These Third-Party Owners may have their
own terms of service, privacy policies or other policies and ask you to agree
to the same. We are not responsible
for these third-party privacy policies or the practices of Third-Party
Owners. Be sure to review any
available policies before submitting any personally identifiable information to
a third-party application or otherwise interacting with it and exercise caution in connection with these
applications. We also encourage you to note when you
leave our Service and to review the
third-party privacy policies of all third-party locations and exercise caution
in connection with them.
6. How
Do I Change My Information and Communications Preferences?
You are responsible for maintaining the accuracy of
the information you submit to us, such as your contact information provided as
part of registration. The Service
may allow you to review, correct or update Personal Information you have
provided through the Service's registration forms or otherwise, and you may
provide registration updates and changes by changing them in your account
registration section. If so, we
will make good faith efforts to make requested changes in our then active
databases as soon as reasonably practicable (but we may retain the prior
information as business records).
With respect to our mobile and other applications (i.e., when we are the
application publisher), you can prospectively stop all collection of
information by the application by uninstalling the application. You may use the standard uninstall
process as may be available as part of your applicable Device or potentially
via the appropriate application or app marketplace. Please note that it is not always
possible to completely remove or delete all of your information from our
databases and that residual data may remain on backup media or for other
reasons. Also, if you have made any
public postings on the Service such as in forums or blogs, these communications
cannot generally be removed. When
you edit your Personal Information or change your preferences on the Service,
information that you remove may persist internally for Genius Brands' administrative
purposes. You may cancel or modify
our e-mail marketing communications you receive from us by following the
instructions contained within our promotional e-mails. This will not affect subsequent
subscriptions and if your opt-out is limited to certain types of e-mails the
opt-out will be so limited. If you
subscribe to text messages from us, you can terminate a particular text message
subscription by reply texting "STOP."
Subsequent or different subscriptions will be unaffected. Please note that we reserve the right to
send you certain communications relating to your account or use of our Service,
such as administrative and service announcements and these transactional
account messages may be unaffected if you choose to opt-out from receiving our
marketing communications. If you
have any questions about the Privacy Policy or practices described in it, you
should contact us in the following ways: Postal Mail: Genius Brands
International, Inc., 301 N. Canon Drive, Suite #305, Beverly Hills, CA 90210 ; By e-mail: info@gnusbrands.com.
7. What
About Transfer of Information to the United States?
Our Service
is operated in the United States and intended for
users located in the United States.
If you are located outside of the United States, please be aware that
information we collect, including Personal Information, will be transferred to,
and processed, stored and used in the United States. The data protection laws in the
United States may differ from those of the country in which you are located,
and your Personal Information may be subject to access requests from
governments, courts, or law enforcement in the United States according to laws
of the United States. By using the Service or
providing us with any information, you consent to the transfer to, and
processing, usage, sharing and storage of your information, including Personal
Information, in the United States as set forth in this Privacy Policy.
8. What
Should Parents Know About Children?
We are a general audience site directed at parents and
teachers. We understand the
importance of protecting children's privacy in the interactive world. We do not use the Service to knowingly
collect personal information that requires parental notice and consent before
collecting under the Children's Online Privacy Protection Act ("COPPA") from children under the age of
thirteen (13). We may provide
sections of the Service that are specifically identified as for kids (or
something similar), in which case we will treat those sections as directed at
children and comply with COPPA, including providing any required notices and
obtaining any required consents.
Sections not identified as for kids are not appropriate for use by
children that are literate and below the age thirteen (13) as these parental
and teacher sections of the Service make available functionality that enables
users to submit, and for us to collect, personal information as defined by
COPPA.
In the event that we become aware that we have
collected Personal Information from any child, we will dispose of that
information in accordance with COPPA and other applicable laws and
regulations. If you are a parent or
guardian and you believe that your child under the age of 13 has provided us
with personal information without applicable COPPA-required consent, please contact
us in the following ways: Postal Mail: Genius Brands International, Inc., 301
N. Canon Drive, Suite #305, Beverly Hills, CA 90210 ; By e-mail: info@gnusbrands.com.
9. What
About Security?
We incorporate commercially reasonable safeguards to
help protect and secure your Personal Information. However, no
data transmission over the Internet, mobile networks, wireless transmission or
electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the
security of any information you transmit to us, and you use our Service and
provide us with your information at your own risk.
10. What
About Changes to the Privacy Policy?
We reserve the right to
change this Privacy Policy at any time.
Any changes will be effective immediately upon the posting of the
revised Privacy Policy and your use of our Service indicates your consent to
the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information
in a manner materially different than represented at the time it was collected
without your consent. If you have a
subscription to a Service, material changes to the Privacy Policy will only
become effective with respect to the aspect of that subscription Service at the
end of the then current applicable term unless you otherwise consent. To the extent any provision of this
Privacy Policy is found by a competent tribunal to be invalid or unenforceable,
such provision shall be severed to the extent necessary for the remainder to be
valid and enforceable.
//End Privacy Policy//