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Privacy Policy and Notice at Collection

Thank you for visiting Responsible Pet Breeders Australia (RPBA). Here at RPBA we are committed to protecting your privacy. As you’ll find below, our privacy policy is centred around your legitimate interest and consent.

This Privacy Policy and Notice at Collection (“Privacy Policy”) explains how RPBA entities (“RPBA”, “us”, “our”, and “we”), collect and use Personal Information (defined below) and sets out the basis on which Personal Information we collect from or about you will be processed by us. This document aims to provide concise, transparent, intelligible and easily accessible information about how we process personal data – please read it.

This Privacy Policy applies to all users of RPBA experiences provided via responsiblepetbreeders.com.au and other related RPBA websites (“RPBA Owned Sites”), and RPBA technology that is integrated on third-party partner websites, app or mobile-device applications (“Partner Sites”) (collectively, “RPBA Sites”). This Privacy Policy also applies to individuals who engage with RPBA in their professional capacity on behalf of their company or employer in business dealings with RPBA. However, this Privacy Policy does not apply where RPBA processes your Personal Information on behalf of any Partners to enable those Partners to serve their own Offers and not those of any other Advertiser. Please consult the privacy policies or notices of those Partners to understand how they use your Personal Information. If you are a RPBA employee or contractor, or if you apply for a job with RPBA, your Personal Information collected in the employment or job applicant contexts will be subject to separate privacy policies that we provide to you where and when appropriate.

What are the consequences of opting into RPBA’s Offers?

There is no obligation for you to sign up to Offers, at all. If you sign up to any Offers, we may share your Personal Information, where applicable, with the party identified in the Offer, so that any Offers they have offered may be fulfilled by them, and so they may provide further information associated with such Offers, as further detailed below under ‘Use and Disclosure of your Personal Information’. Importantly, there are no negative consequences if you do not sign up to an Offer, nor are you prevented from accessing the services in future from that company – simply no further action will be taken in respect of that Offer.

Our commitment to privacy

RPBA takes your privacy very seriously and is committed to protecting it, as well as securing the data entrusted to us by Partners, Advertisers and you. We understand that you will only use our service if you can trust us to protect your Personal Information and use it appropriately. For more information on the steps we take to secure your data, see ‘Information security safeguards’ below.

What is Personal Information?

“Personal Information” or “Personal Data” is information about you which (i) can be used to identify, contact or locate you; (ii) can be combined with other information that is linked to you; or (iii) is defined as “Personal Data” or “Personal Information” by applicable laws or regulations relating to the collection, use, storage or disclosure of information about you. Personal Information includes contact information (e.g. email address, telephone number), online information (e.g. IP addresses, device identifiers), and other data which can be used individually or in combination with other data to identify an individual (such as gender, marital status, age, or postcode).

Types of Personal Information that we collect, when, why and from whom (our basis for processing)

We collect and process a number of categories of Personal Information, on the basis of the legitimate interests of RPBA and its Partners and Advertisers:

  • Personal Information you give us when you engage with us or sign up to Offers across RPBA Sites (such as your name and email address);
  • Personal Information you provide to us through our various customer contact channels (such as your name, email address, phone number, and/or any other personal details you choose to provide when you contact us);
  • Personal Information about you provided to us by Advertisers and Partners (as part of our services to them), such as your identifying details (such as email address, gender, age/DOB, postcode, title, phone number), transaction details or conversion data (such as what you purchased, when and via what method);
  • Data about your interactions with the RPBA Sites and/or Offers or any communications sent on behalf of RPBA, Advertisers or Partners, including:
    • information relating to your Offer interaction, such as Offer click-through rates and viewing data;
    • device information and website analytics information retrieved from your device/web browser, such as your device profile, IP address, browser type/version, language preferences, access times, referring website address, or your general geographic area based on your IP address;
  • Information we automatically obtain using cookies, eTags/cache browsers, pixels, web beacons/GIFs, local storage, or other identifiers or other tracking technologies on RPBA Sites and in e-mails we send you, that tell us the pages you view, the links you click, whether an email has been opened, transaction information and other actions relating to our services and technology;
  • If you engage with RPBA on behalf of your business or employer in furtherance of commercial dealings with us, we will collect Personal Information in the course of managing the relationship, such as your business contact information and our contact history, as well as your login credentials to access your RPBA account.
  • Personal Information about you that we may obtain from third-party sources and platforms (including data validation services, authentication service providers (including for calendaring services), data enrichment providers, social networking sites, online marketing and segmentation providers and ad-targeting companies) to supplement the information we collect from Partners and Advertisers and directly from you. For example, when you sign up to an Offer using your email address, we verify with a validation service that the email address is real, in order to ensure valid registration information and prevent fraudulent signups. In other cases, we may use age verification providers in order to ensure that Offers are appropriate for a particular individual above or below the age of majority, or the age of digital consent.

In some circumstances where we process your Personal Information on the basis of our legitimate interests and those of our Partners and Advertisers, separate consent may be required by law for us to operate our technology (for example, in the case of cookies or other tracking technology that we use to access end user devices or technology that identifies your general location or geographic position). Your consent may be obtained by us or on our behalf by our Partners and Advertisers.

The legitimate business interests referred to above, which have been balanced against the rights and freedoms of data subjects and their reasonable expectations, include:

  • (i) the provision and use of website preference management software and analytics services ensuring customers have the best possible website experience by ensuring that content is relevant, engaging and personalised for each user viewing content on RPBA Sites (e.g. “if you just bought this product, you might like…”) or accords with the Partner’s specified user journey or journey parameters;
  • (ii) the provision and use of website brand management tools to promote brand safety for website users and owners;
  • (iii) ensuring website safety by ensuring Offers presented to users are age-appropriate and shown only to their intended audience (e.g. not to children);
  • (iv) the provision and use of website analytics and conversion tracking tools to assess the transaction attributes to optimise future marketing campaigns and future marketing strategy;
  • (v) the provision of customer and email management software services allowing customers to effectively subscribe or unsubscribe to Offers that may be of interest or value to them;
  • (vi) allowing website owners to recoup the actual cost of providing website services to users;
  • (vii) validating users to verify the accuracy of customer data and to reduce fraudulent signups;
  • (viii) creating and retaining evidential records to validate the provision of consent to direct marketing;
  • (ix) using limited data sets for suppression purposes to prevent further unwanted processing for users who have either (a) objected to direct marketing or (b) have exercised their right to erasure (in respect of Personal Information provided by them), if applicable; and
  • (x) managing our customer relationships with Partners and Advertisers, and overseeing our vendors, service providers, and data processors to ensure compliance with contractual and legal obligations.

Note that, depending on local data protection laws where you are located, you may have a right to object to processing on the above basis – see below under ‘Your rights in relation to your Personal Information’.

Note in order to offer you a more consistent and personalised experience in your interactions with RPBA, information collected through one RPBA service may also be combined with information obtained through other RPBA services.

Use and disclosure of your Personal Information

RPBA’s technology allows us to display Offers from Partners and Advertisers on RPBA Sites, and allows you to sign up to receive communications with respect to such Offers. The following subsections detail how your Personal Information is used by RPBA (i.e. for what purpose), as well as the basis on which we disclose information to our Partners and Advertisers and other third-party processors.

(i) Use of Personal Information by RPBA

We use your Personal Information for purposes including:

  • providing, maintaining, protecting, and improving our technology, products and services,
  • monitoring the effectiveness of our services;
  • selecting, displaying and providing to you Offers that are targeted and customised and personalised to your interests, attributes, preferences and experiences;
    predicting what Offers are relevant and engaging to people like you, based on your known characteristics;
  • disclosing the information to RPBA’s Partners and, if applicable, Advertisers – as set out in the sub-section (ii) below;
  • making our services easier to use by eliminating the need for you to repeatedly enter your information;
  • Offer targeting and suppression purposes, including display retargeting;
  • sending you confirmation messages, further details messages and follow-up reminders for Offers that you have signed up to, via the applicable or appropriate medium including email, SMS, or communicating with you at the telephone number provided or confirmed (which may include using an automatic telephone dialling system or pre-recorded message), on our own behalf and on behalf of Partners and Advertisers;
  • where you have signed up on www.responsiblepetbreeders.com.au or the RPBA Owned Sites, or verbally confirmed with our staff, sending you marketing and promotional materials you have elected to receive;
  • maintaining appropriate legal or business records;
  • enabling us to conduct customer research and develop new services;
  • validating the information you provide to us;
  • verifying your identity in relation to privacy requests you make;
  • to protect our rights, property or safety, our users and employees, or any third-party (incl. Advertisers or Partners);
  • complying with applicable laws and regulations; and
  • if you engage with us in a business-to-business capacity on behalf of your business or employer, in addition to the above, we also use your Personal Information to administer and manage our relationship with you and your employer (such as record keeping, payments, communicating with you, tracking outcomes, and verifying your eligibility and suitability).

We may state a more specific additional purpose when we collect your Personal Information.

(ii) Disclosure of your Personal Information to Advertisers or Partners

  • We disclose your Personal Information (including information you give us and Offer-related information to the Partner) to Partners when you engage with Offers while on the Partner’s site, including by swiping or clicking on Offers;
  • We disclose your Personal Information (including email address and segmentation data (e.g. gender, age/DOB, postcode, title, phone number and third-party provided data), even where this information is not directly displayed on screen), to named Advertisers if you indicate that you wish to accept their Offers (including by swiping or clicking). For example:
Where you sign up to an Offer that involves: We may share the following Personal Information:
Receiving information from an Advertiser via email or otherwise joining their CRM Your email and name, gender, state, country, post code or other location details, age or date of birth, and your device, browser information and transaction information where relevant to the Offer you have accepted (like date or location of an event)
Receiving a call from an Advertiser Your phone number, email and name, gender, state, post code or other location details, age or date of birth, and your device, browser information and transaction information where relevant to the Offer you have accepted (like date or location of an event)
Visiting an Advertiser’s site Your email and name, gender, state, country, post code or other location details, or age but only to pre-populate an online form for your convenience
Signing up to a calendaring invitation or downloading an app Pseudonymized details about you like hashed email for tracking, attribution and custom audience purposes
Other Offer types Information consistent with the nature of the Offer being provided, similar in nature to the details set out above

Electronic Communications – Where a Partner or Advertiser has made an Offer, and you indicate that you wish to accept it (including by swiping and clicking), we disclose your Personal Information to the Partner or Advertiser (as applicable) so that any Offers they have offered may be fulfilled by them, and so they may provide you with further information associated with such Offers to you via the applicable or appropriate medium (including email, SMS, or communicating with you at the telephone number provided or confirmed (which may include using an automatic telephone dialling system or pre-recorded message)). That information is provided to such a party for the purpose of fulfilling the Offer, or other purpose explicitly disclosed at the time of collection, and your information will be handled by that party in accordance with its own privacy policy.

(iii) Further disclosure of your Personal Information

We may additionally disclose your Personal Information as follows:

  • to third-party agents and processors, such as our technology vendors, CRM and data management platforms, data transmission companies, email service providers, data validation service providers, authentication service providers, data enrichment providers, online marketing and segmentation providers; and ad-targeting companies, as applicable, predominantly located in the Australia, for third-party processing;
  • to Advertisers or Partners if you have entered a contest or promotion sponsored by RPBA via their site;
  • to any member of RPBA, meaning subsidiaries of parent company, and their respective professional advisors, directors, employees, contractors and personnel;
  • as required by any law, subpoena, court order, or other enforceable legal process (including laws outside your country of residence);
  • as necessary to detect, prevent, or otherwise address fraud, security or technical issues;
  • as necessary for us to do in order to establish or exercise our legal rights or defend against legal claims; or
  • as part of or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganisation, liquidation, or similar business transaction or corporate event;
  • and for such other purposes that are consistent with the way we have informed you that we will use your Personal Information in this Privacy Policy or at the time we collect your Personal Information; and subject to appropriate confidentiality and security measures.

Disclosure of your Personal Information to recipients ‘overseas’

RPBA processes Personal Information in multiple countries, on high-security servers, possibly located outside the country where you live, with our primary servers located in Australia. Before we disclose your Personal Information to an overseas recipient, we take steps as are necessary and reasonable in the circumstances to help ensure that the overseas recipient does not breach privacy laws in relation to your Personal Information.

Where we disclose your Personal Information to Advertisers and other third-party processors, it is likely (although not assured) the Advertisers or third-party processor will be located in one of the markets in which we operate or have a presence – Australia and any other countries in which we operate as disclosed on our site.

RPBA discloses Personal Information of individuals located in Australia with: (i) suppliers; (ii) other members of the RPBA Group; and (iii) RPBA’s Advertisers and Partners located outside of the Australian Economic Area. Such transfers may be made: (a) to a third country or territory that is assessed by the Australian Commission as ensuring an adequate level of protection; (b) to recipients who have in place appropriate safeguards, such as standard contractual clauses that are approved by the Australian Commission or binding corporate rules that have been approved by a competent supervisory authority; or (c) where a transfer to a third country is occasional and necessary in relation to a contract between us or in your interest or for the establishment, exercise or defense of legal claims.

Information security safeguards

The security of your Personal Information is a priority for us, especially when your personal information is transferred ‘overseas’.

We take appropriate technical and organisational measures (including physical and electronic security) designed to safeguard Personal Information from loss, misuse, unauthorised access, modification or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information. However, no method of online transmission or storage of information is 100% secure, and we cannot guarantee that your Personal Information will always be safe no matter what measures we put in place. Specific measures that we use include:

  • restricting access to Personal Information where practicable;
  • using industry-standard encryption to help protect data in transit and at rest;
  • building and maintaining a secure (private) network with no direct access between the internet and systems processing your data;
  • using pseudonymization techniques such as hashing email addresses or device IDs that we associate with you to reduce the risks when processing that data;
  • conducting regular scans and penetration tests of our applications and networks to identify (and address) any potential vulnerabilities;
  • demanding equivalent security and confidentiality measures from any third parties we do business with.

Data retention

determining how long to retain the Personal Information about you supplied to us by them, subject to you exercising your lawful data subject rights, and further subject to any requirement for us to hold data for such period as may be required to establish, exercise or defend legal rights or ongoing legitimate business interests (e.g. to prove that you signed up to a particular Offer or electronic communication). These periods vary by market in accordance with local laws. Please refer to the ‘Your rights in relation to your Personal Information’ section below for more information about how you can exercise your rights.

In respect of other categories of Personal Information and Personal Information collected on RPBA Owned Sites, if RPBA has no ongoing legitimate business need to process your Personal Information, we will take all reasonable steps to destroy the information and/or ensure that the information is de-identified or anonymized or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

We rely on the following criteria to help determine the appropriate retention periods: (i) the necessity of the Personal Information to provide our services to Partners and Advertisers; (ii) the types and sensitivity of Personal Information being processed; (iii) regulatory requirements that we are subject to, including laws and regulations related to tax, employment, accounting, and securities; and (iv) whether a legal claim might be brought against us, for which the Personal Information would be relevant.

RPBA is not responsible for how long Partners and Advertisers may retain your Personal Information. You should consult the privacy notices provided by Partners and Advertisers with whom you interact in order to determine how long they may retain your Personal Information.

How we use Tracking Technologies

Like many companies, when we display online Offers to you, we may use one or more persistent “Tracking Technologies” (such as cookies, entity tags (eTags), pixels, web beacons/ GIFs, local storage, or other identifiers on your device and browser settings) in order to recognise you and your device each time we display Offers to you. We also apply statistical probabilities to data sets, which attempt to recognise or make assumptions about users and devices (e.g., that a user of multiple devices is the same user). Tracking Technologies may set or alter settings or configurations on your device. We use both session and persistent Tracking Technologies.

We use these technologies for a number of purposes to enhance your online experience, such as for preference setting, Offer selection, analytics, conversion attribution and fraud reduction. By rejecting Tracking Technologies, this does not mean that you will no longer see ads when you visit RPBA Sites.

Further information on our use of Tracking Technologies, and how you can exercise your rights not to accept the use of Tracking Technologies, is set out in our ‘Cookies’ Policy.

What this Privacy Policy does not cover

Where RPBA provides information to a third-party (such as an Advertiser or Partner, for example, in relation to an Offer), you acknowledge that your Personal Information will be handled by that third party in accordance with its own privacy policy and not in accordance with the RPBA Privacy Policy. You should consult our Advertiser’s and Partner’s own privacy policies for further details on their use, disclosure, transmission or storage of your Personal Information.

This policy does not apply to the practices of organisations that RPBA does not own or control, or to people that RPBA does not employ or oversee even if Offers, coupons or links to their websites appear within our technology.

As a marketing technology provider, RPBA does not endorse any specific Partner or Advertisers, nor does it take any responsibility for concluding or finalising Offers on their behalf. RPBA gives you the opportunity to elect to receive information about Offers that you determine are of interest to you – without taking any of your specific personal circumstances into account.

Your privacy rights

Where provided for by applicable law where you are located, you may have a number of rights regarding the processing of your Personal Information, including some or all of the following rights:

  • the right to request access to, or copies of, your Personal Information that we process or control, or have collected or shared about you, together with information regarding the nature, processing and disclosure of that Personal Information (such as (i) the categories of Personal Information that we have collected about you (including sensitive Personal Information); (ii) the categories of sources from which we have collected Personal Information about you; (iii) the business or commercial purpose for collecting your Personal Information; (iv) the categories of Personal Information that we have sold or disclosed about you and the categories of outside parties to whom the Personal Information was sold or disclosed; and (v) information about the logic involved in any automated decision-making processes used by us (if applicable), as well as a description of the likely outcome of the process with respect to you);
  • the right to request rectification of any inaccuracies in your Personal Information that we process or control;
  • the right to request, on legitimate grounds:
    • deletion of your Personal Information that we process or control; or
    • restriction of processing of your Personal Information that we process or control;
    • the right to object, on legitimate grounds, to the processing of your Personal Information by us or on our behalf;
  • the right to request available information on the source of the Personal Data where it is not from you;
  • where we engage in profiling or automated decision-making as defined under applicable laws, you may request to opt-out of such profiling or automated decision-making;
  • the right to request that we limit our use and sharing of your sensitive Personal Information only to those purposes described under applicable privacy laws (e.g. providing our goods and services that you have requested, maintaining the quality of our services, or protecting our platforms against illegal activity);
  • where we rely on your consent to use your Personal Information (e.g. for the sending of direct marketing by electronic mail), the right to withdraw that consent – see below under ‘How do I withdraw consent/ unsubscribe?’
  • where we process your Personal Information on the basis of your legitimate interests, the right to object to the processing of your Personal Information – see below under ‘How do I opt out?’
  • the right to opt-out of the “sale” of your Personal Information and the “sharing” of your Personal Information for cross-context behavioural Advertising – we allow third parties to place their own cookies on RPBA Owned Sites, some of which could be considered a “sale” or “sharing” of your Personal Information under local laws. If you would like to opt out of such cookie-based sales and sharing of your Personal Information on RPBA Owned Sites, you can click the “Do Not Sell or Share My Personal Information” link in the footer below to update your cookie preferences and disable Targeting cookies. Please note that your cookie selections are specific to the device, website, and browser you are using. Your selections are deleted whenever you clear your cookies or browser’s cache.
  • the right to file a complaint with a Data Protection Authority regarding the processing of your Personal Information by us or on our behalf.

Non-discrimination and applicability of these rights

Other users may have similar rights granted to them under local laws. In such case we will act in accordance with those laws. You will not be discriminated against for exercising your privacy rights. We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. As noted earlier, if you are an employee or contractor, or if you are a job applicant, your rights with respect to your Personal Information collected in those contexts will be described in a separate privacy notice that we provide to you where and when appropriate.

How to exercise your privacy rights (including through an authorized agent)

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Policy, or about our processing of your Personal Information, please send an email to [email protected]. To opt-out of cookie-based sales and sharing of your Personal Information for cross-context behavioural advertising on RPBA Sites, click the “Do Not Sell or Share My Personal Information” link at the bottom of this page. You may designate an authorised agent to make a request on your behalf, using the same methods described here. When submitting the request, however, please ensure the authorised agent identifies himself/herself/itself as your authorised agent.

If you are not satisfied with the outcome of your request and would like to request further review, you may send an email to [email protected] with “Personal Information Requests Appeal” in the subject line.

Verification and security

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the Personal Information and the nature of your request. Note as a security measure, to ensure that we properly identify you, such requests will only be actioned in respect of, and confirmed by way of reply email to, the specific email address from which the request was made. Note we will refuse requests made in respect of email addresses which a user cannot access. User requests will be answered as soon as possible but not later than one month after they are made or such other time that may be required under applicable privacy laws.

How do I withdraw consent / unsubscribe from marketing communications?

Withdrawing consent from RPBA for direct marketing communications / unsubscribing

Where you have given your consent for specific purposes, such as sending direct marketing by electronic mail, RPBA provides a facility for you to withdraw such consent for RPBA to process the Personal Information for that purpose. Note there are no adverse consequences for withdrawing your consent.

To unsubscribe from:

  • any specific electronic correspondence from RPBA, use the ‘unsubscribe’ link contained in emails we send you or reply “STOP” to any SMS message you receive;
  • all future email correspondence from RPBA, please send an email to [email protected] with the subject “Withdraw Consent” and we will unsubscribe you from all communications we send you.

Note: if you withdraw consent, we will keep a copy of your email address on file to record that you have withdrawn your consent, and we will retain any information not provided on the basis of consent, and any information to the extent necessary to establish, exercise or defend legal rights. Even if you opt-out, we will still send you non-marketing emails, such as emails about recent transactions or updates to our legal terms.

Withdrawing consent from RPBA’s Advertisers and Partners for direct marketing communications / unsubscribing

In order to withdraw consent from our Advertiser and Partners, to exercise your data subject rights or to otherwise access, update or delete any of your Personal Information retained by them, you should contact them directly.

Where RPBA Advertisers and Partners have integrated with the RPBA unsubscribe mirroring service, where you request to unsubscribe from any further email correspondence from RPBA, you will be presented with the option to also unsubscribe from the applicable RPBA Partner or Advertiser’s communications at the same time. This may only be done by following the unsubscribe link contained in the emails we send you, and will be confirmed at the time of making the unsubscribe.

Otherwise, if you wish to unsubscribe from any further electronic correspondence from a RPBA Partner or Advertiser, you should submit a request to those organisations directly using the unsubscribe facility provided by them, or otherwise as described in their communications to you, or as set out in their privacy policy.

Is unsubscribing the same as opting out?

No. Unsubscribing/ withdrawing consent means we won’t send future electronic communications to you unless you sign up again to subsequent Offers. However, if you want to avoid in the future seeing any third-party Advertiser Offers on RPBA Sites, you should ‘opt out’. The next section deals with Opting Out.

How do I opt out of Offers?

Opting out from Advertiser Offers

RPBA provides a facility for you to opt out of seeing all future third-party Advertiser Offers on RPBA Sites (thereby avoiding any targeted third-party Offers in the future).

To request this please send an email to [email protected] with the subject “Opt Out”. Note we will keep a copy of your email address on file to retain a record that you have opted out. If you use another email with a RPBA Partner, then you may need to opt out from multiple email addresses in order to ensure you don’t see any targeted third-party Offers in future.

Even if you opt out you will still need to unsubscribe directly from any of our Partners’ or Advertisers’ mailing lists if you want to stop receiving electronic communications from them.

Opting out from Partner Offers

Even if you opt out you will still see offers from Partners which are native to the Partner’s site. You cannot opt out from seeing first party Partner Offers.

Children’s privacy

RPBA does not allow advertisements to be targeted at individuals under the age of 18.

RPBA does not knowingly collect Personal Information from or about children under the age of 18. If we learn that we have collected Personal Information of a child under the age of 18, we will delete that data from our systems.

RPBA encourages parents and guardians to monitor their children’s activities online.

Complaints

RPBA treats complaints relating to privacy very seriously. If you submit a concern or complaint, we will endeavour to deal with it comprehensively and reach an outcome with which all parties are satisfied. If you have any questions concerning any element of this Privacy Policy, or privacy complaints, please contact the privacy team at [email protected].

Changes to this Privacy Policy

RPBA may update this Privacy Policy at any time. If we do so, we will post any Privacy Policy changes on our website, which you can review at any time. You will also be presented with this Privacy Policy whenever you are shown Offers on RPBA Sites. Your continued use of such services after any change will signify and confirm your assent to changes to our Privacy Policy.

Whom to contact about this policy

RPBA’s Data Protection Officer can be contacted via [email protected].

Version: August 2023

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