Rowing The World's Privacy Policy
The website https://rowingtheworld.com/ (the “Site”) is operated by Marr Consulting International Ltd. operating as Rowing the World and Travel2Row (collectively, also referred to as “Rowing the World”, “us”, or “we”). We respect your right to control your personal information. That is why we have developed this privacy policy (the “Privacy Policy”) which describes:
- the types of personal information we collect about you;
- the purposes for which we collect that information;
- how we use that information;
- with whom we share that information;
- how we safeguard that information;
- the choices available to you regarding how we use your personal information; and
- how you can contact us about our privacy practices.
This page contains the Privacy Policy for the Site, as well as for any other websites or microsites operated by Rowing the World (collectively and together with the Site, the “Sites”), and for any web applications, mobile applications, tools, forums, or social media pages offered by Rowing the World on the Sites, and for any online services offered by Rowing the World, including but not limited to information about past and upcoming Trips that we offer, blog posts, and retail services allowing you to provisionally register for spots on available Trips (together with the Sites, the “Service”).
By accessing or using the Service, you consent to the collection, use and disclosure of personal information by Rowing the World in accordance with this Privacy Policy. You may choose not to provide us with personal information. You also have the right to withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. However, if you choose not to provide your consent or to withdraw your consent, we may not be able to provide you with the application, service or information that you request.
If you are providing personal information on behalf of someone else, you acknowledge that you have obtained express consent from that individual for you to use the Service and provide information on their behalf.
We recommend that you read this Privacy Policy in its entirety to ensure that you are fully informed. However, you can access specific sections of this Privacy Policy based on the type of information you are looking for by clicking on the links below.
- What are the key defined terms used throughout this Privacy Policy?
- What personal information do we collect?
- What is the purpose of the collection and use of your personal information?
- To whom do we disclose your personal information?
- How do we obtain your consent? How do you withdraw your consent to the collection, use or disclosure of your personal information? Are any circumstances where your consent is not obtained?
- What if there is a change in the initial purpose for the collection of your personal information?
- Do we knowingly collect personal information about children?
- How do we safeguard your personal information?
- Do we transfer your personal information to third parties for storage or processing?
- How long do we retain your personal information?
- Do we collect, use, and disclose non-personal information about you?
- How do we ensure the accuracy of your personal information
- How can you access your personal information?
- What types of “cookies” and/or other technologies do we use and how can you change your “cookie” settings?
- Do we have links to other websites on the Service? If so, which privacy policy governs?
- Do we use third party advertising partners? If so, how can you opt out of targeted advertising?
- What type of analytics services do we use and for what purpose? How can you disable analytics?
- What do you need to know about the basis for collection, using, and processing your personal information and your associated personal information rights if you are located within the European Union (“EU”) or the European Economic Area (“EEA”)
- Who do you contact if you have an inquiry, complaint, or want to request a review of your personal information?
- How do we handle complaints?
- How can you unsubscribe from our commercial electronic messages such as messages regarding new products or services
- If changes are made to this Privacy Policy, will you be notified? If so, how will you be notified?
1. Definitions
For the purposes of this Privacy Policy, the following words have the following meanings:
“collection” means the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.
“consent” means voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative, such as a parent or guardian. Express consent is permission that is granted by an individual taking a positive step to signify consent and may be given orally, electronically or in writing. Implied consent is the assumption of consent that can reasonably be inferred from a user's action or inaction.
“disclosure” means making personal information available to a third party.
“employee” means an employee of Rowing the World, and for the purpose of this Privacy Policy only, includes agents, independent and other contractors performing services for Rowing the World.
“non-personal information” means information that does not identify a specific individual and which we are unable to connect to other information in order to identify a specific individual.
“Organization” means a company, entity or organization, including any business, but does not include an individual.
“personal information” means information about an identifiable individual, but not aggregated information that cannot be associated with a specific individual.
“registered user” means a user who has created and registered an account or accounts with Rowing the World, as well as an Organization that has created and registered an account or accounts with Rowing the World.
“third party” means an individual other than the user, or the user's agent, or an organization other than Rowing the World or an Organization, other than the user.
“Third Party Sites” means any third-party websites, web applications, mobile applications, tools, forums made available to you as part of a trip.
“Trip” means any rowing trip listed by us on the Service for which you provisionally register and/or attend, including any custom trips.
“use” means the treatment, handling and management of personal information by and within Rowing the World.
“user” means an individual who visits the Sites and/or accesses the Service and/or uses the Service, as well as an Organization which visits the Sites and/or accesses the Services and/or uses the Service.
2. Personal Information We Collect
When you interact with us through the Service, we may collect or receive the following types of information.
Personal Information You Provide to Us
You may provide us with your personal information in different ways. For example, we may collect any or all the following personal information if the information is reasonably required to provide the Service to you:
- information that you provide when you become a registered user or otherwise complete forms on the Service, such as your name, company name, birth date, email address, social media user ID, postal address, telephone number, and country of residence;
- your log-in and password details in connection with your Rowing the World account(s), including your username;
- information that you provide to Rowing the World when you subscribe to the Service, such as your billing address, payment method and credit card information;
- information that you provide while registering for a particular Trip, such as:
- your name, phone number (including one we can use to reach you during a Trip, if different), birth date, gender, email address, registration type, whether you have rowed with us before, any medical or dietary conditions you may have,
- information about your rowing and swimming skills, experience, and preferences, including the name of your rowing club, the name and contact information of your club president or coach, and your National Federation Membership Number,
- the name, phone number, email address, and city and country of residence of your emergency contact,
- information about how and when you plan to arrive at a Trip starting point, including whether and where you will be staying at a Trip starting point prior to departure on a Trip,
- information about how you plan to depart from a Trip ending point,
- proof of health insurance, including the name of your insurer and your plan number, and/or documentation from your insurer,
- any special occasion you may be celebrating during a Trip, if you choose to share,
- your preferred room type for the duration of a Trip,
- if you are planning a custom Trip, information about your preferences for such a Trip,
- if you are travelling with another person or people, the information listed above in Sections 2(d)(i) through 2(d)(ix) about that individual or those people, and
- your billing information.
- your correspondence with Rowing the World employees or independent contractors, including any questions, concerns or comments you may have about the Service or problems that you report;
- comments, videos, photographs, and any other content or information that you may submit to the Service; and/or
- details of your requests made through the Service.
All purchases of Rowing the World services being made via debit or credit will be directed to and handled by third parties such as Worldline. You will be bound by the privacy policies of these third-party sites. If you pay via cheque or wire transfer, Rowing the World may have access to certain account number information provided by you for the purpose of facilitating that payment.
Technical Information We Collect Automatically
When you visit the Service, we may collect, using electronic means, technical information. This information may include:
- the IP address of your computer and which browser you used to view our Service;
- operating system;
- resolution of screen;
- location;
- language settings in browsers; and/or
- the site you came from and searched for keywords if arriving from a search engine.
This technical information (some of which in certain instances may be considered personal information) is aggregated and used to measure and improve effectiveness of our Service. We do not attempt to combine this technical information with other personal information we collect on our Service.
Personal Information Posted by You or Others to the Service
If you voluntarily submit or post any information, videos, photographs or other content (“User Content”) to the Service, or to any Third Party Sites, certain of your personal information may be included in the posting, such as your username, email address, and image, and this information may be collected and used by others. Rowing the World has no control over and is not liable for the collection, use or disclosure of any posted User Content or your included personal information by users of the Service or the Third Party Sites. You are responsible for ensuring the protection of any of your personal information that you post to any other user’s account, Rowing the World messaging account or to the Sites, the Service, or Third Party Sites. The term “User Content” does not include aggregated non-personal data as described in Section 11 of this Privacy Policy.
3. Purpose of Collection and Use of Personal Information
Rowing the World collects your personal information and will use your personal information as is reasonably required for the following purposes:
- if you are a registered user, to establish and maintain your Rowing the World account,
- to provide web applications, the Service, and/or the other services or information that you request,if applicable, to plan for a safe and enjoyable Trip, including to:
- assess and verify your physical fitness and suitability for a Trip. Individuals attending on our Trips need a certain level of rowing and swimming experience and skill in order to participate in a safe and enjoyable manner, which we need to verify for your benefit as well as the benefit of other individuals registered for the same Trip,
- ensure we have met the requirements of rowing clubs that may host us on a Trip,
- plan activities for the duration of a Trip,
- plan accommodations for the duration of a Trip,
- plan for arrival prior to a Trip and departure after a Trip,
- contact you during a Trip,
- confirm that you have health insurance suitable for a Trip, and
- obtain your emergency contact information for use in case of an emergency during a Trip,
- to verify your identity if you submit comments, videos, photographs, opinions, or any other content or information to the Service,
- to respond to questions, comments, requests, job applications, or complaints that you submit to Rowing the World,
- to collect amounts owing from you to Rowing the World, if applicable,
- to process payments made by you to Rowing the World, depending on your method of payment,
- to track communications with you,
- to analyze use of the Service and to improve the Service,
- to send emails, newsletters, regular mail or other communications you have consented to receive from Rowing the World,
- to provide Service-related announcements or notifications to you,
- to aggregate your personal information resulting from the combination and/or aggregation of certain raw personal information collected from you with other data in a way that no longer personally identifies you,
- to display advertising on the Service or to manage and serve our advertising on other sites. See Section 16 on targeted advertising and how you may opt out,
- to fulfill a purpose that we disclose to you when we request your personal information, and/or
- to meet legal and regulatory requirements.
Your personal information will only be collected and used by Rowing the World and our employees, independent contractors, agents, partners and service providers in a manner consistent with the activities of Rowing the World. Access to your personal information by Rowing the World employees, independent contractors, agents, partners and service providers is limited only to those authorized, based on their need to deal with the personal information for the reason(s) for which it was obtained, including to enable them to perform a business, professional or technical support function for Rowing the World.
4. Disclosure and Personal Information
Rowing the World may disclose your personal information to:
- its employees, independent contractors, agents, partners, distributors, retailers and service providers as is reasonably necessary to enable these parties to perform a business, professional or technical support function for Rowing the World;
- a person who, in the reasonable judgment of Rowing the World, is seeking the information as your agent; and
- your emergency contact, where in the reasonable judgement of Rowing the World it is necessary to respond to an emergency;
- the individual you identified as your rowing club president or coach, in order to verify the information you provided about your skills and experience; and
- any other third party or parties, where you consent to such disclosure, or the disclosure is permitted or required by law.
5. Consent
Different types of consent may be appropriate in different circumstances. Where personal information is particularly sensitive, the purpose for which we collect it is outside of your reasonable expectations, or where it creates a meaningful risk of significant harm, express consent is required and will be obtained separately.
There are some limited circumstances where consent is not required for the collection, use and disclosure of your personal information. For example, we may disclose personal information without your knowledge or consent for the purpose of collecting a debt you owe to us. We will only process your personal information without your knowledge or consent where this is permitted or required by law.
You may withdraw your consent to the collection, use or disclosure of your personal information by Rowing the World at any time, subject to legal or contractual restrictions and reasonable notice. In certain circumstances, your withdrawal of consent may result in the inability of Rowing the World to continue providing aspects or optimization of the Service to you. Please contact Rowing the World as provided in Section 19 for more information regarding the implications of withdrawing consent.
6. Change of Purpose
Rowing the World will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and obtain your consent to do so pursuant to Section 22.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
7. Children
The Service is intended for general audiences and is not directed to children under the age of 16. We do not knowingly collect personal information from children under the age of 16. In the event that we learn that we have collected personal information from a child under the age of 16, we will take appropriate steps to delete that personal information. If you become aware or believe that a child has provided us with personal information, please contact us as provided in Section 19.
8. Safeguarding Your personal information
Rowing the World is committed to safeguarding your personal information. Rowing the World uses appropriate security measures to protect personal information against risks such as loss or theft, unauthorized access, disclosure, copying, misuse, modification or destruction, and any other unlawful form of processing of the personal information in our possession regardless of the format in which it is held. The methods of protection and safeguards used by Rowing the World include, but are not limited to:
- Administrative safeguards such as privacy policies and procedures;
- Technical safeguards such as vulnerability scans and technological measures, including the use of passwords, encryption, firewalls, and secure coding frameworks;
- Physical safeguards such as need-to-know access for Rowing the World employees, independent contractors, agents, partners, and service providers.
In any organization, failure to protect personal information can increase the risk of a privacy breach which can lead to things such as financial loss, reputational harm, fraud, or identity theft. While Rowing the World cannot guarantee that a privacy breach will not occur, Rowing the World will make every effort to prevent such occurrences by implementing the above security safeguards.
Rowing the World also ensures that its employees, independent contractors, agents, partners, and service providers with access to personal information are made aware of the importance of maintaining the confidentiality of personal information.
Rowing the World takes care in disposing of or destroying personal information to prevent unauthorized parties from gaining access to the information.
While Rowing the World is committed to safeguarding your personal information, we cannot ensure or warrant the security of any personal information we collect either directly or automatically from you, and you provide your personal information at your own risk.
Rowing the World can not guarantee that such personal information may not be accessed, disclosed, altered, or destroyed by breach of any of our security safeguards. To the degree that personal information is of a sensitive nature, in the event of a breach, there may be a risk of significant harm to you which includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record and damage to or loss of property.
Rowing the World also cannot guarantee that information sent or received over the Internet is secure and does not make any representation or warranty concerning the security of personal information communicated to or from Rowing the World via the Internet or regarding the interception by third parties.
9. Cross Border Transfer of Personal Information
Subject to any contractual restrictions as between Rowing the World and an Organization, your personal information may be stored and processed in any country (e.g. Canada, United States) where we engage third party service providers. While such information is outside of your country of residence, it is subject to the law of the country in which it is held, and may be subject to disclosure to the governments, courts, law enforcement agencies or regulatory agencies of such other country, pursuant to the laws of such country. For example, personal information stored in the United States is subject to the USA PATRIOT ACT. However, our practices will always continue to be governed by this Privacy Policy.
Rowing the World has measures in place to ensure that during cross-border transfers of your personal information the personal information is subject to appropriate safeguards in accordance with data protection laws. These measures typically include contractual safeguards stipulating the confidentiality of the information and the purposes for which it is to be used.
Where and when appropriate, we will transmit amended personal information to third parties having access to the personal information in question.
10. Retention of Personal Information
Rowing the World will only keep personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Privacy Policy and to comply with our legal and regulatory obligations. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
11. Non-Personal Information
Rowing the World may collect, use, and disclose non-personal information, including aggregated data resulting from the combination and/or aggregation or certain raw data collected from you with other data in a way that no longer personally identifies you. We make no attempt to link this non-personal information with the identity of individuals. We may permanently archive non-personal information for future use in any manner whatsoever.
12. Accuracy Personal Information
Rowing the World is committed to keeping your personal information as complete, up-to-date, and accurate as is necessary for the purposes for which it is to be used. Rowing the World will promptly correct or complete any personal information found to be inaccurate or incomplete. Where appropriate, Rowing the World will transmit amended information to third parties having access to the personal information in question.
13. Access of Personal Information
Upon request, Rowing the World will provide you with a reasonable opportunity to review the accuracy of your personal information. Such personal information will be provided within a reasonable time of the request and at a minimal or no cost to you.
Also upon request, Rowing the World will provide an account of the use and disclosure of your personal information and, where reasonably possible, will state the source of the information. In providing an account of disclosure, Rowing the World will provide a list of organizations to which it may have disclosed personal information about you when it is not possible to provide an actual list.
In certain circumstances, Rowing the World may not be able to provide access to all the personal information we hold about you. In such a case, we will provide the reasons for denying access upon request. Such reasons may include:
- if doing so would likely reveal personal information about another individual that cannot be severed, or the information could reasonably be expected to threaten the life or security of another individual;
- if doing so would reveal any of our confidential information;
- if the information is protected by solicitor-client privilege;
- if the information was generated during a formal dispute resolution process; or
- if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law, or that of a foreign jurisdiction.
Individuals can obtain information or seek access to their personal information by contacting our Privacy Officer pursuant to Section 19 of this Privacy Policy during regular business hours.
15. Links and Other Websites
The Service may contain links to other sites, such as Facebook, Instagram, YouTube, Twitter, and LinkedIn. This Privacy Policy only applies to personal information that we collect, use and disclose. We are not responsible or liable for the privacy practices of third parties, and we strongly recommend that you review their privacy policies before you disclose personal information to them.
16. Targeted Advertising and How You May Opt Out
We may use third party advertising partners such as advertising networks, exchanges, and social media platforms to display advertising on the Service or to manage and serve our advertising on other sites. Most modern web browsers contain extensive controls that give you the ability to make choices about your privacy. These controls may enable you to block or limit cookies, which are used in targeted advertising, or add on utilities such as ad blockers or other tools.
17. Analytics
The Service utilizes Google Analytics, a web analysis service from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses "cookies," which are text files placed on your computer, to help the website analyze how users use the Service, compiling reports on the activity of the Service for the Services’ operators and providing other services relating to website activity and Internet usage. The information generated by the cookie (including the IP address) is transferred and stored on a Google server located in the United States.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other information held by Google.
We may also use additional analytics programs from time to time to process non-personal information about you.
We make no attempt to link this non-personal information with the identity of individuals using the Service. Non-personal information may be permanently archived for future use in any manner whatsoever by Rowing the World.
Disable Google Analytics
You can prevent the collection and processing of cookie created data relating to your utilization of the Service (including your IP) via Google by downloading and installing the browser-plugin available under the following link (https://tools.google.com/dlpage/gaoptout?hl=en).
Google currently offers this opt-out tool for Google Chrome, Mozilla Firefox, Apple Safari and Microsoft Edge.
Further information concerning the terms and conditions of Google’s use and data privacy can be found at https://www.google.com/analytics/terms/us.html or at https://policies.google.com/privacy.
18. Additional EU and EEA Disclosures
Legal Basis for Processing Your Personal Information
Our legal basis for collecting and using personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which we collect it.
Below are the types of lawful basis that, depending on the circumstances, we may rely on to process your personal information:
| Legal Basis for Processing | Explanation of Legal Basis |
|---|---|
| Consent | You have given consent to us for the processing of your personal information for one or more specific purposes. |
| Legitimate Interest | Processing your personal information to enable us to provide and improve the Service to you, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. Where we rely on legitimate interests as a lawful ground for processing your personal information, we balance those interests against your interests, fundamental rights and freedoms. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at as provided under Section 19. |
| Performance of Contract | Processing your personal information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. |
| Comply with a legal or regulatory obligation | Processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject. |
Change of Purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
Your Personal Information Rights
Under certain circumstances and in accordance with EU/EEA applicable data protection laws, you have the following rights:
| Right | Explanation of Right |
|---|---|
| Right of Access | The right to make a written request for details of your personal information and a copy of that personal information. |
| Right to Rectification | The right to have inaccurate information about you corrected or removed. |
| Right to Erasure (‘Right to be Forgotten’) | The right to have some or all of your personal information erased. |
| Right to Restriction of Processing | The right to request that your personal information is only used for restricted purposes. |
| Right to Automated Decisions | The right to contest any automated decision made where such a decision is based solely on automated processing, including profiling, which produces legal effect concerning you or similarly significantly affects you, unless you have expressly consented to it or it is necessary for entering into, or performance of, a contract for the provision of services to you or otherwise authorized by applicable law. |
| Right to Object | The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests. |
| Right to Data Portability | The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format. |
| Right to Withdraw Consent | The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent. |
To exercise any of these rights, please contact us as provided in Section 19. These rights are not absolute and they do not always apply in all cases.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request in order to help us respond efficiently to your request.
You will not have to pay a fee to access your personal information (or to exercise any of the above rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
If you have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us as provided under Section 19.
19. Contact Us
To submit an inquiry, complaint, request a review of your personal information, correct or update your personal information, withdraw your consent or request more information or additional copies of this Privacy Policy contact:
Rowing the World Privacy Officer
Mailing Address: 904 Grosvenor Avenue, Winnipeg, Manitoba, Canada, R3M 0N4
Telephone No.: (204) 995-3496
E-mail: row@rowingtheworld.com
20. Complaints
Rowing the World will promptly investigate all complaints concerning our compliance with this Privacy Policy and our dealings with your personal information. If a complaint is found to be justified, Rowing the World will take appropriate measures to resolve the complaint, including, if necessary, amending our policies and procedures. You will be informed of the outcome of the investigation regarding your complaint.
21. Unsubscribe from Commercial Electronic Messages
We may send you commercial electronic messages (such as marketing or promotional messages) if you have:
- provided us with your express consent to receive these messages;
- recently purchased a product or service from us;
- entered into a contract with us or some other form of business relationship with us;
- requested information from us; or
- applicable law otherwise permits us to send commercial electronic messages to you.
If you no longer wish to receive commercial electronic messages from Rowing the World regarding our new products or services, promotions, or other similar communications, you may unsubscribe using the mechanism provided in each message. Please note that, after you unsubscribe, Rowing the World may still send electronic communications to you in certain limited circumstances, such as to provide you with Service notifications and billing information, or to provide information that Rowing the World is legally obligated to provide you.
22. Privacy Policy Changes
We may modify this Privacy Policy to accommodate changes in our services, changes in technology and legal developments. If we make changes to this Privacy Policy, we will provide notice through the Service, or by other means to provide you the opportunity to review the changes before they become effective. For example, we may place a prominent notice on the Service or e-mail you to let you know of an updated Privacy Policy.
If we make significant changes to this Privacy Policy, we will provide at least 30 days’ notice through the Service, or by other means, to provide you the opportunity to review the changes and provide your required consent before they become effective. A significant change may be using personal information for a new purpose or disclosures to new third parties.
As outlined above, consent may be express or implied. The type of consent required depends on the circumstances. Where the changes are such that we require your express consent, we will seek it. Otherwise, you acknowledge that your continued use of the Service after we modify this Privacy Policy, publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.
If you object to any changes to this Privacy Policy you may close your account.
Whenever we update this Privacy Policy, we will change the date below to indicate when the changes were made.
Date: August 24, 2023