Terms of Service and Privacy Policy

/Terms of Service and Privacy Policy
Terms of Service and Privacy Policy 2013-12-01T05:33:35+00:00
1. Your Acceptance

This is an agreement between Avante Security Inc., a corporation located in Toronto, Ontario, Canada (“Avante”), the owner and operator of www.avantesecurity.com (the ” Site”), the Avante software and hardware, including but not limited to the Avante Smartboxx and its other various security and technology components, the Avante Relay Control App and the Just-In-Case App (collectively, including all content and services provided by Avante, the “Avante Service”, or the “Service”), and you (“you” or “You”), a user of the Site or the Service. BY USING THE SITE OR THE SERVICE, YOU ACKNOWLEDGE AND AGREE TO THESE TERMS OF SERVICE, AND AVANTE’S PRIVACY POLICY, AND WHICH ARE INCORPORATED HEREIN BY REFERENCE. If you choose to not agree with any of these terms, you may not use the Site or the Service.

2. Avante Service

These Terms of Service apply to all users of the AvanteSite and/or Service. Information provided by our users through the AvanteSiteand/or the Servicemay contain links to third party websites that are not owned or controlled by Avante. Avante has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party websites. In addition, Avante will not and cannot censor or edit the content of any third-party site. By using the Site and/or the Service, you expressly acknowledge and agree that Avante shall not be responsible for any damages, claims or other liability arising from or related to your use of any third-party website or services.

3. Avante Access

A. Subject to your compliance with these Terms of Service, Avante hereby grants you permission to use the Site or the Service, provided that: (i) your use of the Service as permitted is solely for your personal use, and you are not permitted to resell or charge others for use of or access to the Siteand/or Service, or in any other manner inconsistent with these Terms of Service; (ii) you will not duplicate, transfer, give access to, copy or distribute any part of the Siteand/or the Service in any medium without Avante’s prior written authorization; (iii) you will not attempt to reverse engineer, alter or modify any part of the Site and/or the Service; and (iv) you will otherwise comply with the terms and conditions of these Terms of Service and Privacy Policy. B. You expressly acknowledge and agree that in order to access and use the features of the Siteand/or the Service, you may have to provide some personal data, such as names, addresses or email addresses, mobile phone numbers etc. We DO NOT collect this data (names, addresses or email addresses or mobile phone numbers). You are solely responsible for the messages that you submit on the Site and/orthrough the Avante Service. Although Avante will not be liable for your losses caused by any unauthorized use of your account, you may be liable for the losses of Avante or others due to such unauthorized use.
C. You agree not to use or launch any automated system, including without limitation, “robots,” “spiders,” “offline readers,” etc. or “load testers” such as wget, apache bench, mswebstress, httpload, blitz, XcodeAutomator, Android Monkey, etc., that accesses the Site and/or the Servicein a manner that sends more request messages to the Avante servers in a given period of time than a human can reasonably produce in the same period by using anAvanteService or Site, and you are forbidden from ripping the content unless specifically allowed. Notwithstanding the foregoing, Avante grants the operators of public search engines permission to use spiders to copy materials from the website for the sole purpose of creating publicly available searchable indices of the materials, but not caches or archives of such materials. Avante reserves the right to revoke these exceptions either generally or in specific cases. While we don’t disallow the use of sniffers such as Ethereal, tcpdump or HTTPWatch in general, we do disallow any efforts to reverse-engineer our system, our protocols, or explore outside the boundaries of the normal requests made by Avante clients. We have to disallow using request modification tools such as fiddler or whisker, or the like or any other such tools activities that are meant to explore or harm, penetrate or test the Site and/or the Service. You must secure our permission before you measure, test, health check or otherwise monitor any network equipment, servers or assets hosted on our domain. You agree not to collect or harvest any personal identification information, including phone number, from the Service, nor to use the communication systems provided by the Service for any commercial solicitation or spam purposes. You agree not to spam, or solicit for commercial purposes, any users of the Service.

4. Intellectual Property Rights

The design of the Avante Service along with Avante created text, scripts, graphics, interactive features and the like, except User Submissions (as defined below), and the trademarks, service marks and logos contained therein (“Marks”), are owned by or licensed to Avante, subject to copyright and other intellectual property rights under Canada and foreign laws and international conventions. The Service or the Site is provided to you AS IS for your information and personal use only. Avante reserves all rights not expressly granted in and to the Service or the Site. You agree to not engage in the use, copying, or distribution of any of the Service or the Site other than expressly permitted herein, including any use, copying, or distribution of User Submissions of third parties obtained through the Service for any commercial purposes. 

5. User Submissions

A. Components of theAvante Service allow Avante users to receive alarms and submit and send text, photos, voice clip(s), location data and other communications submitted by you (collectively, the “User Submissions”). These User Submissions may be hosted, shared, and/or published as part of the Avante Service, and should be available to the contact(s) that you choose to submit theaforementioned information. For clarity, alarms will be sent directly to you and/or your preferred contact(s) and text messages will be sent directly to your contact(s) of your choice. Text message, photos, voice clip(s) and location data will only be viewable by those contact(s) you directly send such information.

B. You shall be solely responsible for your own User Submissions and the consequences of sending them. Because Avante is only acting as a repository of data, user submitted information do not necessarily represent the views or opinions of Avante, and Avante makes no guarantees as to the validity, accuracy or legal status of any information. In connection with User Submissions, you affirm, represent, and/or warrant that: (i) you own or have the necessary licenses, rights, consents, and permissions to use and authorize Avante to use all patent, trademark, trade secret, copyright or other proprietary rights in and to any and all User Submissions to enable inclusion and use of the User Submissions in the manner contemplated by the Service and these Terms of Service; and (ii) you have the written consent, release, and/or permission of each and every identifiable individual person in the User Submission to use the name or likeness of each and every such identifiable individual person to enable inclusion and use of the User Submissions in the manner contemplated by the Service and these Terms of Service. To be clear: you retain all of your ownership rights in your User Submissions, but you have to have the rights in the first place. However, by submitting the User Submissions to Avante, you hereby grant Avante a worldwide, non-exclusive, royalty-free, sublicenseable and transferable license to use, reproduce, distribute, prepare derivative works of, display, and perform the User Submissions in connection with the Avante Service and Avante’s(and its successor’s) business, including without limitation for promoting and redistributing part or all of the Avante Service (and derivative works thereof) in any media formats and through any media channels. You also hereby grant each subscriber to your information on the Avante Service a non-exclusive license to access your User Submissions through the Service. The foregoing license granted by you terminates once you remove or delete a User Submission from the Avante Service.

C. In connection with User Submissions, you further agree that you will not: (i) submit material that is copyrighted, protected by trade secret or otherwise subject to third party proprietary rights, including privacy and publicity rights, unless you are the owner of such rights or have permission from their rightful owner to post the material and to grant Avante all of the license rights granted herein; (ii) publish falsehoods or misrepresentations that could damage Avante or any third party; (iii) submit material that is unlawful, obscene, defamatory, libelous, threatening, harassing, hateful, racially or ethnically offensive, or encourages conduct that would be considered a criminal offense, give rise to civil liability, violate any law, or is otherwise inappropriate; (iv) post advertisements or solicitations of business; (v) impersonate another person; (vi) interfere with or disrupt the integrity or performance of the Service or the data contained therein; or (vii) attempt to gain unauthorized access to the Service or the Site or its related systems or networks.

D. Adult content must be identified as such. Avante does not endorse any User Submission or any opinion, recommendation, or advice expressed therein, and Avante expressly disclaims any and all liability in connection with User Submissions. Avante does not permit copyright infringing activities and infringement of intellectual property rights via its Service, and Avante will remove all content and User Submissions if properly notified that such content or User Submission infringes on another’s intellectual property rights. Avante reserves the right to remove content and User Submissions without prior notice. Avante may also terminate a user’s access to the Service, if they are determined to be a repeat infringer, or for any or no reason, including being annoying. A repeat infringer is a User who has been notified of infringing activity more than once and/or has had a User Submission removed from the Service more than twice. An annoying person is anyone who is (capriciously or not) determined to be annoying by authorized Avante employees, agents, subagents, superagents or superheros. Avante also reserves the right to decide whether content or a User Submission is appropriate and complies with these Terms of Service for violations other than copyright infringement and violations of intellectual property law, such as, but not limited to excessive length or limited interest. Avante may remove such User Submissions and/or terminate a User’s access for sending such material in violation of these Terms of Service at any time, without prior notice and at its sole discretion.

E. You understand that when using the Avante Service and/or Site that Avante is not responsible for the accuracy, usefulness, safety, or intellectual property rights of or relating to User Submissions, and that such User Submissions are not the responsibility of Avante. You further understand and acknowledge that you may be exposed to User Submissions that are inaccurate, offensive, indecent, or objectionable, and you agree to waive, and hereby do waive, any legal or equitable rights or remedies you have or may have against Avante with respect thereto, and agree to indemnify and hold Avante or its parent company Avante Logixx Inc., its officers, directors, employees, agents, affiliates, and/or licensors, harmless to the fullest extent allowed by law regarding all matters related to your use of the Avante Service.

F. Avante permits you to link to materials on the Service for personal purposes only. Avante reserves the right to discontinue any aspect of the Avante Service at any time. 

6. Warranty Disclaimer

YOU AGREE THAT YOUR USE OF THE AVANTE SERVICE AND/OR SITE SHALL BE AT YOUR SOLE RISK. TO THE FULLEST EXTENT PERMITTED BY LAW, AVANTE OR ITS PARENT COMPANY AVANTE LOGIXX INC., ITS OFFICERS, DIRECTORS, EMPLOYEES, AND AGENTS DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, IN CONNECTION WITH THE SERVICE AND YOUR USE THEREOF. AVANTE MAKES NO WARRANTIES OR REPRESENTATIONS ABOUT THE ACCURACY OR COMPLETENESS OF THIS SERVICE’S CONTENT AND ASSUMES NO LIABILITY OR RESPONSIBILITY FOR ANY (I) ERRORS, MISTAKES, OR INACCURACIES OF CONTENT, (II) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO AND USE OF OUR SERVICE, (III) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION AND/OR FINANCIAL INFORMATION STORED THEREIN, (IV) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM OUR SERVICE, (IV) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE WHICH MAY BE TRANSMITTED TO OR THROUGH OUR SERVICE AND/OR SITE THROUGH THE ACTIONS OF ANY THIRD PARTY, AND/OR (V) ANY ERRORS OR OMISSIONSIN ANY CONTENT OR FOR ANY LOSS OR DAMAGE OF ANY KIND INCURRED AS A RESULT OF THE USE OF ANY CONTENT POSTED, EMAILED, TRANSMITTED, OR OTHERWISE MADE AVAILABLE VIA THE AVANTE SERVICE. AVANTE DOES NOT WARRANT, ENDORSE, GUARANTEE, OR ASSUME RESPONSIBILITY FOR ANY PRODUCT OR SERVICE ADVERTISED OR OFFERED BY A THIRD PARTY THROUGH THE AVANTE SERVICE OR ANY HYPERLINKED WEBSITE OR FEATURED IN ANY USER SUBMISSION OR OTHER ADVERTISING, AND AVANTE WILL NOT BE A PARTY TO OR IN ANY WAY BE RESPONSIBLE FOR MONITORING ANY TRANSACTION BETWEEN YOU AND THIRD-PARTY PROVIDERS OF PRODUCTS OR SERVICES. AS WITH THE PURCHASE OF A PRODUCT OR SERVICE THROUGH ANY MEDIUM OR IN ANY ENVIRONMENT, YOU SHOULD USE YOUR BEST JUDGMENT AND EXERCISE CAUTION WHERE APPROPRIATE. 

7. Limitation of Liability

IN NO EVENT SHALL AVANTE OR ITS PARENT COMPANY AVANTE LOGIXX INC., ITS OFFICERS, DIRECTORS, EMPLOYEES, OR AGENTS, BE LIABLE TO YOU FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE, OR CONSEQUENTIAL DAMAGES WHATSOEVER RESULTING FROM ANY (I) ERRORS, MISTAKES, OR INACCURACIES OF CONTENT, (II) PERSONAL INJURY OR PROPERTY DAMAGE, OF ANY NATURE WHATSOEVER, RESULTING FROM YOUR ACCESS TO AND USE OF OUR SERVICE, (III) ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION AND/OR FINANCIAL INFORMATION STORED THEREIN, (IV) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM OUR SERVERS, (IV) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE, WHICH MAY BE TRANSMITTED TO OR THROUGH OUR SERVICE BY ANY THIRD PARTY, (V) ANY ERRORS OR OMISSIONS IN ANY CONTENT OR FOR ANY LOSS OR DAMAGE OF ANY KIND INCURRED AS A RESULT OF YOUR USE OF ANY CONTENT POSTED, EMAILED, TRANSMITTED, OR OTHERWISE MADE AVAILABLE VIA THE AVANTE SERVICE, WHETHER BASED ON WARRANTY, CONTRACT, TORT, OR ANY OTHER LEGAL THEORY, AND WHETHER OR NOT THE COMPANY IS ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, AND/OR (VI) THE DISCLOSURE OF INFORMATION PURSUANT TO THESE TERMS OF SERVICE OR PRIVACY POLICY. THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW IN THE APPLICABLE JURISDICTION. YOU SPECIFICALLY ACKNOWLEDGE THAT AVANTE SHALL NOT BE LIABLE FOR USER SUBMISSIONS OR THE DEFAMATORY, OFFENSIVE, OR ILLEGAL CONDUCT OF ANY THIRD PARTY AND THAT THE RISK OF HARM OR DAMAGE FROM THE FOREGOING RESTS ENTIRELY WITH YOU.
The Service and the Site is controlled and offered by Avante from its facilities in Canada. Those who access or use the Avante Service and/or Site from other jurisdictions do so at their own volition and are responsible for compliance with local law. 

8. Indemnity

You agree to defend, indemnify and hold harmless Avante, its parent corporationAvante Logixx Inc., officers, directors, employees and agents, from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses (including but not limited to attorney’s fees) arising from: (i) your use of and access to the Avante Service; (ii) your violation of any term of these Terms of Service; (iii) your violation of any third party right, including without limitation any copyright, property, or privacy right; or (iv) any claim that one of your User Submissions caused damage to a third party. This defense and indemnification obligation will survive these Terms of Service and your use of the Avante Service and/or the Site.

9. Ability to Accept Terms of Service

You affirm that you are either of age of consent, or an emancipated minor, or possess legal parental or guardian consent, and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in these Terms of Service, and to abide by and comply with these Terms of Service.

10. Assignment

These Terms of Service, and any rights and licenses granted hereunder, may not be transferred or assigned by you, but may be assigned by Avante without restriction.

11. General

You agree that: (i) the Avante Service and/or Site shall be deemed solely based in Canada; (ii) the Avante Service and/or Site shall be deemed a passive server that does not give rise to personal jurisdiction over Avante, either specific or general, in jurisdictions other than Canada; and (iii) that you agree to subject to the jurisdiction of Canada in the event of any legal dispute. These Terms of Service shall be governed by the internal substantive laws of Canada, without respect to its conflict of laws principles. Any claim or dispute between you and Avante that arises in whole or in part from the Avante Service and/or Site shall be decided exclusively by a court of competent jurisdiction located in Toronto, Ontario, Canada. These Terms of Service and Privacy Policy and any other legal notices published by Avante, including, but not limited to an end user license agreement, shall constitute the entire agreement between you and Avante concerning the Avante Service and the Site. If any provision of these Terms of Service is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of these Terms of Service, which shall remain in full force and effect. No waiver of any term of this these Terms of Service shall be deemed a further or continuing waiver of such term or any other term, and Avante’s failure to assert any right or provision under these Terms of Service shall not constitute a waiver of such right or provision. Avante reserves the right to amend or modify these Terms of Service at any time, and it is your responsibility to review these Terms of Service for any changes. If you do not agree to the revised Terms, your only recourse is to discontinue the use of the Avante Service and/or the Site. Your continued use of the Avante Service and/or the Site following any amendment of these Terms of Service will signify your assent to and acceptance of its revised terms. YOU AND AVANTE AGREE THAT ANY CAUSE OF ACTION ARISING OUT OF OR RELATED TO THE AVANTE SERVICE AND/OR SITE MUST COMMENCE WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES. OTHERWISE, SUCH CAUSE OF ACTION IS PERMANENTLY BARRED. 

Privacy Policy

Avante Security Inc. (“Avante”) recognizes that its clients, visitors and users, want to know Avante’s privacy policy. Avante provides this Privacy Policy to help you make an informed decision about whether to use or continue using the AvanteService and/or Site. If you do not agree to our practices, please do not use the Avante Service and/or the Site.
This Privacy Policy is incorporated into and is subject to the Avante Terms of Service. Your use of the Avante Service and the Site and any personal information you provide on the AvanteServiceand the Site remains subject to the terms of this Privacy Policy and our Terms of Service.
What Does This Privacy Policy Cover?
This Privacy Policy is part of Avante’s Terms of Service and covers the treatment of user information, including personal identification information, obtained by Avante, including information obtained when you access the Avante’s Site and/or use the Avante Service.
This Privacy Policy does not apply to the practices of companies that Avante does not own or control, or to individuals whom Avante does not employ or manage, including any of the third parties to which Avante may disclose user information as set forth in this Privacy Policy.

 

The Information Avante Collects
Avante may obtain the following types of information from or concerning you or your mobile phone device, which may include information that can be used to identify you as specified below (“Personal identification information”):
Personal identification information: You provide certain personal identification information, such as your mobile phone number, billing information (if applicable) and mobile device information (if applicable) to Avante when choosing to participate in various uses of the Avante Service, such as registering as a user.
Cookies Information:
When you visit the Avante Site, we may send one or more cookies – a small text file containing a string of alphanumeric characters – to your computer that uniquely identifies your browser. Our Site may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

How we use collected information

Avante Security Inc. may collect and use Users personal information for the following purposes:

  • – To improve customer service
    Information you provide helps us respond to your customer service requests and support needs more efficiently.
  • – To improve our Site or Service
    We may use feedback you provide to improve our products and services.
  • – To send periodic emails
    We may use the email address to respond to their inquiries, questions, and/or other requests.

The Information Avante Does Not Collect
Avante does not collect names, emails, addresses or other contact information from its mobile app and website, users’ mobile address book or contact lists. We do not collect location data, but users may voluntarily share their location, photos, sound clips with other users via the Avante Service.
The contents of messages that have been delivered by the Avante Service (mobile apps) are not copied, kept or archived by Avante in the normal course of business. The contents of any delivered messages are not kept or retained by Avante — the only records of the content of any delivered messages reside directly on the sender’s and recipient’s mobile devices (and which may be deleted at the user’s option). Notwithstanding the above, Avante may retain date and time stamp information associated with successfully delivered messages.
The Way Avante Uses Information
If you submit personal identification information to us through the Avante Site, or the Avante Service, then we use your personal information to operate, maintain, and provide to you the features and functionality of the Avante Site and Avante Service.Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.We may collect and use of personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law. We will only retain personal information as long as necessary for the fulfillment of those purposes. We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.

Our Site is in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for Users.

When Avante Discloses Information
We do not sell, trade, or rent Users personal identification information to others. We do not share generic aggregated demographic information to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may collect and release Users personal identification and/or non-personal- identification information if required to do so by law, or in the good-faith belief that such action is necessary to comply with state and federal laws (such as Canada Copyright Law), international law or respond to a court order, subpoena, or search warrant or equivalent, or where in our reasonable belief, an individual’s physical safety may be at risk or threatened. Avante also reserves the right to disclose personal identification information and/or non-personal- identification information that Avante believes, in good faith, is appropriate or necessary to enforce our Terms of Service, take precautions against liability, to investigate and defend itself against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Avante Site or our servers, and to protect the rights, property, or personal safety of Avante, our users or others.
Your Choices
You may, of course, decline to submit personal identification information through the Avante Site or the Avante Service, in which case Avante may not be able to provide certain services to you. If you do not agree with our Privacy Policy or Terms of Service, please delete your account(s), uninstall the Avante mobile application(s) and discontinue use of the Avante Service; your continued usage of the Avante Service  and/or the Site will signify your assent to and acceptance of our Privacy Policy and Terms of Service. Please contact Avante via email to support at info@avantesecurity.com or available web forms with any questions or comments about this Privacy Policy, your personal information, your consent, or your choices.
Third-party Advertisers, Links to Other Sites
Some of the ads may be served by Google. Google’s use of the DART cookie enables it to serve ads to Users based on their visit to our Site and other sites on the Internet. DART uses “non personally identifiable information” and does NOT track personal information about you, such as your name, email address, physical address, etc. You may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy at http://www.google.com/privacy_ads.html

Our Commitment To Data Security
Avante uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to Avante and you do so at your own risk. Using unsecured Wi-Fi or other unprotected networks to submit messages through the Avante Service and/or the Site is never recommended. Once we receive your information, Avante makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Avante may post a notice on the Avante Site if a security breach occurs.
Changes and updates to this Privacy Notice
Avante Security Inc. has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using Avante Service and/or Avante Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Service and/or our Site. Your continued use of the Service and/or Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

If you have any questions about the Term of Service and Privacy Policy, the practices of the Service and/or the Site, or your dealings with the Service and/or the Site, please contact us at:
Avante Security Inc.
1959 Leslie Street
Toronto, Ontario
M3B 2M3
Canada

Phone: (416) 923-6984
Fax: (416) 923-5198
website: www.avantesecurity.com
email: info@avantesecurity.com

Date Last Modified:
This Privacy Policy was last modified November 19th, 2013