WorkMyWay Privacy Notice

This Privacy Notice explains what you can expect regarding the collection, use and disclosure of your personal information by ManpowerGroup Global Inc., with its registered office in 100 Manpower Place, Milwaukee, WI 53212, and its subsidiaries and affiliates listed here (as applicable, hereinafter each separately and/or jointly called the "Data Controller", “We”, “Our” or “Us”).

The privacy notice describes the types of personal information we collect, how we use it, how we protect it, and for how long we retain it. The notice also outlines disclosures and international transfers and your rights under applicable data protection law regarding our processing of your personal data, including how you can contact us to exercise your rights or enquire more about our privacy practices. Our privacy practices are aligned across the countries in which we operate.

Who this Privacy Notice applies to

This privacy notice applies to:

Candidates, who are individual recipients of our career services and associated jobs and opportunities which may include opportunities with ManpowerGroup or its end clients;
Representatives of our business partners and clients, who are organizational recipients of our career services.

This privacy notice does not apply to our employees, who are individuals employed by ManpowerGroup and who work directly for ManpowerGroup, nor any ManpowerGroup associate consultants that we engage with, from time to time, to deliver specific services.

What is ‘Personal Information’ or ‘Personal Data’?

Personal Information, also referred to as Personal Data, is information that whether alone, or combined with other information, allows you to be identified directly, or indirectly. Common personal data identifiers are attributes like your name, online identifier, or ID numbers. However, a combination of one or more elements specific to your physical, physiological, genetic, psychological, economic, cultural, or social identity may also be identifiable personal information, given their potential to identify you when combined.

Some personal data types are considered more sensitive than others and the definition of sensitive data varies by local law. Across several major privacy laws, sensitive data examples include health data, ethnic and racial origins, political opinions, genetic and biometric data, an individual’s sex life or sexual orientation, religious/philosophical beliefs, trade union membership, precise geolocation and government issued identifiers.

Personal Information We Collect

Depending on the nature of our relationship with you, we will collect different types of personal data in a variety of ways. The personal information we collect will be limited to what is necessary to achieve the purposes stated in this notice that are relevant to the nature of the relationship.

Candidate Data Collection Sources

Proactive 3rd party sourcing: We conduct pro-active searches for talent from a variety of 3rd party resources, for example, job boards, social media. We will add the personal data collected to our database to link you to an open vacancy or a talent pool and we may share a link for you to sign up to our talent community or apply for a specific role.
Candidate applications via 3rd party sites: We advertise job opportunities on a variety of 3rd party sites; if you apply, your personal data will be collected in our database to progress the opportunity and, where applicable, support you with other opportunities.
Candidate applications or registration via WorkMyWay sign-up / careers pages: We use WorkMyWay to offer careers sign up pages, where individuals can register to join talent pools for existing and future opportunities. Individuals can also apply for job opportunities directly from this site.
Via client representatives: From time to time, our client representative may disclose information to us regarding individuals that may be suitable for specific roles, or broader opportunities. In such scenarios we may ask you to review and accept our terms in order to provide you with career services.

Candidate Data Collection Types

Depending on your stage in the recruitment process, we may collect the following information:

First name, last name, preferred name and, if you register on our Sites, your username and password;
Email address, telephone number, social media URL;
Your preferred contact channels;
Your CV/Resume, which may include a personal/professional summary, employment and education history, professional memberships, qualifications, licenses, language proficiencies and other work-related skills and abilities;
Employment related details from your social media or job board profile. If we provide the ability to parse your social media or job board profile instead of uploading your CV/Resume, you will be able to edit and amend the parsed information, giving you full control over what information you use to create your profile;
Information you provide to confirm we can offer you opportunities, for example, that you are over 18 years old and have the to work in a particular country;
Information you provide regarding your career interests, salary expectations, and other information about your employment suitability and preferences;
Information you provide about other people you would like us to contact, for example, for references. When you provide us with this information, we assume the individual gave you authorisation for such communication;
Call recordings, call transcripts and call summaries;
Message transcripts and message summaries;
Essential and non-essential cookies, web beacons and web server logs by automated means, consistent with your consent preferences;
Dates, timestamps, and other records of our interactions with you in relation to the career sites and services we provide;
Device information and browser locale preferences, e.g. your language and time zone;
Results of assessments - reports and/or scores;
Date of birth;
Other information you may provide to us directly in any form (during an interview or other related communication).

Business Partner and Client Representatives

If you are a client or any other third-party business partner representative, we will collect information in connection with our interactions to deliver and make available the agreed services. This may include, but is not limited to your:

First and Last Name;
Organization name;
Business email address and contact information;
Job details, such as your role, your office/work location;
A record of communication, which may include call recordings, call transcripts and call summaries.

How we use the personal information we collect

All processing of personal information will be carried out in compliance with applicable laws. When we use personal data, we strive to minimize it to what is necessary to achieve the intended result.

If you use our career services, we will use your personal data, or a portion of your personal data for the following purposes:

providing career services and connecting you to opportunities;
assessing your suitability for available positions and/or talent pools, including job matching and scoring;
scheduling screening calls/interviews with you;
identifying you and/or authenticating your identity;
managing your WorkMyWay account if you have chosen to register on our site. You can edit your profile and adjust the optional information you have disclosed to us at any time;
sending you updates and notifications regarding the services you are receiving, and other related communications, consistent with your communication preferences;
optimizing and personalizing your user experience (please also consult the “Terms of Use” and Cookie Notice we publish on our site footer);
tailoring and personalizing the support we offer based on eligibility, suitability, and other criteria;
responding to queries, claims, and requests for assistance;
performing data analytics, such as;

analysing interactions and usage across WorkMyWay and associated careers sites,
analysing our job candidate base,
assessing individual performance and capabilities,
identifying skill shortages,
using information to match individuals and potential opportunities,
analysing pipeline data (trends regarding hiring practices),
determining the effectiveness of our engagement strategy,
determining the effectiveness of our recruitment marketing/advertising campaigns, and
overall, determining the effectiveness of our products and services.

aggregating data as part of our analytics efforts;
anonymising or pseudonymising data as part of our analytics efforts;
enhancing, modifying, personalizing, or otherwise improving our services for the benefit of our candidates, clients and our own operations;
auditing our interactions, transactions, accounting and other internal compliance functions;
protecting against, identifying, and seeking to prevent fraud, deceptive practices and other unlawful activity, claims and other liabilities;
enhancing the security of our network and information systems;
complying with and enforcing applicable legal requirements, exercise or defence of legal claims, relevant industry standards, contractual obligations, and our policies;
managing our business partner relationships;
communicating around the services we offer, programs, events, offers, surveys, evaluations, and market research;
in a way consistent with the cookie notices we place on our Sites.

We do not, and will not, sell your personal data. We will never use the information you provide us for cross-contextual advertising (also referred to as “sharing” or “targeted advertising”).

When applicable data protection law requires a lawful basis for processing personal data, our processing will be carried out based on one or more of the following lawful grounds for processing:

Acceptance of our Terms / Contract of Service;
Legitimate business purpose, for example, to enhance, modify, personalize or otherwise improve our services;
Legal obligation, to the extent the processing is necessary to help us comply with our legal and regulatory obligations.

Where none of the lawful grounds listed above applies, or where required by applicable data protection law, we rely on your consent to process your personal data. We will affirmatively request your consent, for example, when you tick a box to give permission based on your understanding of the nature of the processing.

Artificial Intelligence (AI) / Machine Learning

Our career services are enabled by AI, which may include Machine Learning. With the assistance of AI, we can connect individuals with suitable opportunities, get people into work more efficiently, provide visibility on job market trends, and enhance our overall productivity.

ManpowerGroup is committed to transparent, trustworthy and safe AI and in line with our AI Policy, before deploying any AI tools, we conduct thorough risk assessments to safeguard individuals' rights. We commit to audit and testing of our AI systems to detect and prevent bias. AI does not replace human judgment and therefore there is always human oversight in our AI assisted processes. At any stage in our delivery of the services, you can ask us for more information and/or express your point of view about any of our processes or decisions involving you.

Examples of how we use AI in our Services:

Candidate CV/Resume parsing: We use AI to parse both an individual's CV/Resume and job descriptions. Parsing this information creates a semantic representation of both, which can be used at a later point for job matching, scoring and ranking. Semantics are learned from publicly available data and job taxonomies using machine learning, while neural networks are trained to learn the representation of each skill. For example, the technology can recognise the explicitly mentioned skill of ‘catering’ and associate it with other nearby skills that do not explicitly mention catering, like ‘restaurant management’ ‘private events’ ‘hospitality industry’ ‘food & beverage’ etc.
Candidate scoring / ranking: We use two separate AI models to helps recruiters match, score and rank candidate experience, skills, and other job-related criteria available against job opportunities. With the first model, scores are derived based on how closely the candidate’s skills profile matches the required skills/attributes obtained from the job description. The candidate is scored only against the job/skills match and not against other candidates. Our second model is used for talent rediscovery within the existing talent pool; it creates a match score that is derived from a combination of both the job/skills profile match and its ranking adjustment relative to the matches of the rest of the candidate population in the talent pool.
Candidate sourcing: AI agents help to scan our talent pool to identify candidates that are a potential match to new opportunities.
Candidate engagement: Our voice and text AI can engage with candidates to provide visibility on career opportunities, gather supplementary information to update the candidate profile and perform some automated candidate qualification, determining whether the candidate meets minimum requirements such as right to work. The engagement agent can send information updates and reminders where applicable.
Interview scheduling: AI helps us coordinate interviews between the candidates and recruiters or client representatives and recruiters.
Interview transcript and summarization: Based on transcriptions of the AI agent or human recruiter voice call, and/or the AI agent SMS/WhatsApp message interactions, we use AI to summarise the communications, enhancing productivity and supporting faster recruitment related processes.
Data quality: we use AI to timely and accurately update the database with the information obtained during the activities mentioned above.

While AI augments recruitment processes, the final decision to reject qualified candidates for an opportunity is always made by a recruiter. We do not intend to use AI to collect or process any sensitive data, and we do not permit AI automated decisions that are based on sensitive data. We do not use your personal data to train our AI systems.

By continuing to use our career services, you agree our use of AI for the purposes described here in.

If you have any questions relating to our use of AI, please contact us via the details provided in the How to Contact Us section, below.

How we Protect Personal Information

We maintain technical and organisational measures designed to protect the personal data we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Such measures ensure an appropriate level of security taking account, on one hand, the technical state of the art and, on the other hand, the sensitive nature of Personal Data and the evaluation of potential risks;

To ensure the appropriate security and confidentiality of personal data, we apply to the following non-exhaustive list of measures:

Encryption of data at rest and in transit using industry standard encryption algorithms with appropriate key lengths;
Strong user authentication and role-based access controls;
Network monitoring solutions with events logging;
Hardened network infrastructure;
Measures for ensuring physical security of locations at which personal data are processed;
Business continuity and disaster recovery plans with periodic testing;
Incident management policy and processes;
Periodic vulnerability and penetration testing;
Certification/assurance of processes and products;
Periodic employee privacy and security training and awareness program;
Third party privacy and security assessments;
Risk assessments to ensure data protection by design and default;
Robust data processing and confidentiality agreements; and
Organizational measures for ensuring data minimization, purpose limitation, retention, data quality and accountability.

How Long We Store the Information We Collect

We will keep your personal data for the period necessary to achieve the purposes described in this privacy notice, taking into account the nature of our relationship with you, applicable statute of limitation periods and records retention requirements under applicable law and/or Terms. Subject to applicable law, we will retain your personal data as required to meet our business and compliance obligations, for example, to comply with our tax and accounting obligations.

We store the information we collect in a way that identifies data subjects for no longer than is necessary considering the purposes for the processing. We determine this specific period of time by considering:

the necessity to store the information collected to offer services to the user;
the existence of specific legal obligations that make the processing and related storage necessary for specific period of times.

Candidates

Upon receipt of your personal data, we may contact you by email, SMS, messaging app, Teams call and/or telephone call and request that you review our User Agreement to proceed with our career services. If you do not agree to our User Agreement, your personal data will be deleted from our database within 30 days.

If you have accepted our User Agreement, your personal data will be kept in our database for two years, as specified in our User Agreement, which you can view [here]. During this term, we will send you emails about career opportunities, or reminders to e.g. update your preferences or update your CV/Resume. At any point, you can opt out of these emails by clicking unsubscribe at the bottom of the email. However, we may still contact you on an individual basis.

You will be contacted by email two years after your acceptance to the User Agreement to determine whether you wish to remain registered for job opportunities. You will receive three reminders and if you do not reply, your data will be erased from the candidate pool, in full, within 30 days. If you inform us that you wish to remain registered, we will re-validate your acceptance of our User Agreement every two years.

At any time during our services, you can ask us to delete your data by exercising your privacy rights and choices.

Candidates who have taken up employment or assignment with an employer are advised to contact the employer directly if they also wish to have their data removed from the employer's systems/databases.

Any candidates sourced by ManpowerGroup, that ManpowerGroup determine are not likely to be aligned with any of the current or future opportunities, will be deleted from the talent pool within 30 days.

How We May Disclose Personal Information

We may disclose your personal data to vendors, for example, IT providers that perform services on our behalf, based on our instructions, to make the Sites and associated career services available to you.

We strive to ensure this data is minimized to what is necessary to perform the specific services instructed. We do not authorise these vendors to use or disclose the personal information except as necessary to perform services on our behalf or comply with legal requirements. Personal data will not be sold, rented, distributed or made available to vendors for their own commercial purposes, including for their direct marketing purposes.

We also may disclose your personal data to (i) our subsidiaries and affiliates; (ii) clients who may have job opportunities available or interest in placing our job candidates; and (iii) others with whom we work, such as consultants to provide the relevant career services or staffing suppliers who work with us to fill vacancies and place people into work.

In addition, we may disclose your personal data about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials in response to a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

International Data Transfers

We may transfer the personal data we collect about you to countries outside of the country in which the information originally was collected. The laws of those countries may not provide the same of data protection as the laws of the country in which you initially provided the personal data.

When we transfer your information to other countries, we will protect that data as described in this privacy notice and any other specific notice given to you at the time of, or prior to, the transfer. Such transfers will comply with applicable law.

When we transfer personal data from within the European Economic Area, the United Kingdom or Switzerland, to countries that do not benefit from an adequacy decision by the competent supervisory authority, transfers will take place on the basis of:

binding corporate rules;
standard contractual clauses (SCCs) adopted by the European Commission, along with the mandatory adoption provisions required for the UK and Switzerland to the extent the processing involves UK or Swiss residents.

Where transfers rely on SCCs, transfers will only take place after a transfer impact assessment of;

The legal practices of the recipient country relating to access to data;
The technical and organizational measures adopted to protect the data; and
The nature of the processing to ensure purpose limitation and data minimization.

Subject to applicable law, you may obtain a copy of these safeguards by contacting us as indicated in the How to Contact Us section below.

Data Privacy Framework

ManpowerGroup (including ManpowerGroup Global Inc., Right Management LLC and ManpowerGroup Talent Solutions LLC) complies with the EU-US Data Privacy Framework (EU-US DPF), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US DPF) as set forth by the US Department of Commerce. ManpowerGroup has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) under the UK Extension to the EU-US DPF. ManpowerGroup has certified to the US Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (Swiss-US DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF. If there is any conflict between the terms in this privacy policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In the context of onward transfers, ManpowerGroup is accountable for the processing of personal data it receives under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on its behalf. ManpowerGroup remains liable under the EU-U.S. DPF Principles, and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles if ManpowerGroup’s agent processes personal information in a manner inconsistent with the EU-U.S. DPF Principles, and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF Principles, unless ManpowerGroup proves that it is not responsible for the event giving rise to damage.

The Federal Trade Commission has jurisdiction over ManpowerGroup’s compliance with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF. In certain situations, ManpowerGroup may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, ManpowerGroup commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact ManpowerGroup using the information provided in the How to Contact Us section of this notice.

In compliance with the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF, ManpowerGroup commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-US DPF, the UK Extension to the EU-US DPF, and the Swiss-US DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, ManpowerGroup commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF in the context of the employment relationship.

For complaints regarding EU-US DPF, the UK Extension to the EU-US DPF, and Swiss-US DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction

Your Privacy Rights and Choices

When authorized by applicable law, and subject to applicable limitations and exceptions, you may exercise specific rights, such as:

Right to know: you have the right to obtain confirmation about whether personal data concerning you is being processed, and, where that is the case, to know the specific pieces of personal data belonging to you that we hold.
Right to access: you have the right to receive a copy of the personal information that we maintain about you.
Right to rectification: you have the right to request we correct or update any inaccurate or incomplete data held about you, in order to protect the accuracy of such information.
Right to erasure: you have the right to request that we delete and/or destroy information about you and no longer process that data. There might be latency in deleting information from servers and backed-up versions might exist for a short period after account deletion. Please note that erasure is not an absolute right; there may be legal or regulatory reasons to retain some, or all, of the data collected and this will be made clear to you if this is the case, for example to comply with our tax and accounting regulations.
Right to restriction of processing: you can request that we restrict the processing of your personal data.
Right to data portability: you have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format. You have the right to request we transmit this data directly to another data controller/business.
Right to object: you may object, at any time, to the data processing on a number of grounds as set out under applicable laws, without needing to justify your decision. If you object, the previous processing of data will remain lawful.
Right to obtain human intervention to express your point of view and/or to contest any automated decisions. You can request human intervention to review and contest any automated decisions. Please note, in our processes, the final decision to reject qualified candidates for an opportunity is always made by a human so this right is non-applicable.
Right to Opt-Out of the selling and sharing of your personal information: please note, we do not and will not sell or share your personal information as defined in USA privacy laws, so this right is not applicable to our processes.
Right to withdraw consent, you may withdraw your consent to the processing of your personal information, at any time, where you previously consented to the processing of your personal information. Any withdrawal shall not affect the lawfulness of processing based on your consent before its withdrawal, and we continue to retain the personal information that you provided us before you withdrew your consent for as long as allowed or required by applicable law.
Right to lodge a complaint with a supervisory authority: you have the right to lodge a complaint with a supervisory authority in the country or state of your habitual residence, place of work or place of the alleged infringement, if you consider the processing of your personal data infringes privacy law.

If you require more information about the processing of your personal data, please refer to the How to Contact Us section below.

How to Exercise your Privacy Rights and Choices

If you wish to exercise any of your data privacy rights or choices that you cannot perform yourself, you can do so via our Privacy Request Portal.

One of our team may contact you directly, or via our secure online portal, to verify your email address and thereafter your identity, before we can support your request further. As part of this ID verification process you may be asked to provide a government issued ID and/or utility bill. We will permanently delete the verification information that you provide promptly after we have completed the verification process. We are only required to respond to requests that are verifiable and legitimate. If we cannot verify your identity based on the processes described, we may ask you for additional verification information. We will not use that information for any purpose other than verification.

If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity and process your request.

Additional Information for California Residents

This section applies only to job candidates and users who reside in the state of California in the United States (“California Residents”). This section applies to personal information collected through the Site and in any other way.

Categories of Personal Information

The personal information that we collect from and about you listed in the section of the privacy notice entitled, “Personal Information We Collect” falls within the following categories of personal information identified in the California Consumer Privacy Act (“CCPA”): (a) Identifiers, (b) Professional or Employment-Related Information; (c) Internet or Other Similar Network Activity; (d) Non-Public Education Information, (e) Commercial Information, (f) Audio, Visual, and Similar Sensory Information, and (g) Preferences.

Categories of Sources

The personal information that we collect from and about you listed in the section of the privacy notice entitled, “Personal Information We Collect” may come from following sources:

You: for example, in your registration to our talent pool, in any forms you fill out for us, opportunities you are screened for, roles you apply for, assessments you complete, surveys you complete, and any information you provide us during the course of our recruitment processes.
Third parties: for example, our affiliated companies, prospect employers (our clients) and job boards providing recruiter access to non-public information or services.
Public internet sources: for example, job-related social media platforms, job boards, public profiles, and other public online sources
Vendors and service providers: for example, contracted entities who provide various data processing services including but not limited to data storage and hosting, call recording, transcription and summarization.
Automated technologies: for example, on our WorkMyWay careers site, to track logins and activity on our careers page.
Recording technologies, for example, our service provider voicemail technologies and audio/video recording technologies, to the extent permitted by law.

How to Exercise Your Rights

You can submit your request via our online Privacy Request Portal. Alternatively, you can write to us at the address provided in the ‘How to Contact Us’ section below.

Note on Deidentified Information

At times, we convert personal information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”). We maintain Deidentified Information in a deidentified form and does not attempt to reidentify it, except that we may attempt to reidentify the information solely for the purpose of determining whether its deidentification processes ensure that the information cannot be associated with the individual. We prohibit vendors from attempting to reidentify our Deidentified Information.

Links to External Tools and Resources

We may provide links to external third-party websites operated by organizations not affiliated with ManpowerGroup. We do not disclose your personal information to organizations operating such linked third-party websites and we do not review or endorse, and are not responsible for, the privacy practices of these organizations. We encourage you to read the privacy policy of each website that you visit. This Privacy Notice applies solely to information collected by ManpowerGroup and its subsidiaries and affiliates through the services.

Updates to Our Privacy Notice

From time to time, we may modify this Privacy Notice to reflect changes in technology, privacy practices and legal updates, or for other continuous improvement purposes. For significant changes, we will notify you by indicating at the top of each notice when it was most recently updated.

If we add additional services, or modify existing services, that we believe materially changes the nature of the processing you have been made aware of in this Privacy Notice and associated privacy notices provided to you in the delivery of our services, we will make reasonable efforts to provide you with additional notice. By continuing to use the services after such notice, you agree to the terms of the revised Privacy Notice.