Privacy Policy

Privacy Policy

This Privacy Policy will tell you what information NuMi by Nutrisystem®  from Nutrisystem, Inc. (“NuMi by Nutrisystem,” “NuMi”, “we,” or “us”) collects when you and others visit and interact with our website at my.numi.com (“Site”) and use our mobile application (“Application,” or “App”) on a mobile device (“Device”), and platforms where the policy is located (the “Platform”), how we use it and what choices you have about how that information is used. We collect information from you and other users in connection with the provision of our weight loss services and programs (collectively, “Services”).

We urge you to read our entire Privacy Policy so that you will understand both our commitment to you and your privacy, and how you can participate in that commitment.

I. Information You Voluntarily Provide

Personal/Contact Information

When you interact with our App and Site, for example, creating a profile on our Site, we may collect your name, e-mail address, age, height and weight, and other data detailed in the section below.  The personally identifiable information we collect when you register for membership on our App or Site may be used for the purposes outlined in this Privacy Policy, including

  1. to fulfill your requests for Services
  2. to provide you with offers from Nutrisystem and its affiliates
  3. for administrative purposes
  4. for marketing purposes
  5. to enhance your experience with us
  6. to contact you when necessary
  7. as further described in detail in Section IV below

When you use our App and/or Site, we also collect your basic health profile information when you actively give us such information by allowing push notifications to your Device. The health and age information we collect allows NuMi by Nutrisystem to provide you with dietary options according to your physical profile. You will be notified at registration if your profile excludes you from participation in the App and/or Site. NuMi by Nutrisystem will not disclose your health and age information (including self-reported height and weight) to third parties. When you use our App, you may provide NuMi with your log-in credentials for your Nutrisystem.com profile, in order to purchase certain items directly from Nutrisystem.

TYPES OF INFORMATION WE COLLECT

The information we may obtain from you depends on the context of your interactions with us and may include the following:

  • Account information. For example, we may collect your contact information that you provide including name, mailing, billing or shipping addresses, unique personal and online identifiers, birthdate, telephone number, authorization credential tokens, credit card and payment information, email addresses, and mobile phone number.
  • Health and biometric data. If you create a user account, we may collect the information you submit, including your age, gender, and health information that you choose to provide, such as your current weight and goal weight, height, BMI, body type, exercise activity, food consumption and diet, and biometric data including voice recordings and DNA submitted in conjunction with DNA testing.
  • Careers. For example, we may collect your resume and employment and education history when you apply for a job on our platform.
  • Content that you post. This includes content posted on our Platform or sent to us in a message through the “Contact Us” page, chat, blogs, or call center.
  • Social media information. This includes online information about you that you or others have posted.

 

Information Provided in Optional Surveys

We may periodically ask members to participate in online surveys or fill out online questionnaires concerning topics such as the effectiveness of the weight loss program, advertising effectiveness and customer satisfaction. All surveys and questionnaires are optional, and the information collected will not be associated with any user’s personal information. Information gathered may be shared with third parties in order to improve customer satisfaction and program effectiveness. No personal information of any user will be connected to survey or questionnaire results.

Other Information You May Voluntarily Provide

From time to time, we may collect third-party email addresses or other contact information from our users and customers so that we may send information to their friends and family on an as-requested basis.

 

II. Information Collected Automatically

We may collect information about how you, automatically or passively, such as how you use our Site, including commercial information which relates to products (“Products”) or Services in which are you are interested or have considered or purchased. We may also collect personal information about your purchasing habits, or consuming history or tendencies. We may also collect the type of Device you use to access our Site, including Device identifier, IP address, and geolocate information.

We also collect non-personally identifiable information through our Internet log files, which record data such as browser types, domain names, how you interact with an advertisement, and other anonymous statistical data involving the use of our Site. We may also look at how often you use the App and where you downloaded it. This information may be used for our business purposes.   We may link this information to personally identifiable information for these and other purposes, including personalizing your experience on our Site.  Information is also collected when you use our app Handheld Products, including the software application needed to utilize the Handheld Products on your handheld Device (the “Application”). During the installation of the Application and subsequent synchronizations, we collect non-personally identifiable information concerning your Device (such as the specific type of operating system and hardware you have, and the amount of free and total memory) and the Application’s files on your Device.

Our Handheld Products also collect information about your usage of the Application (such as the dates you last synced with the Internet or the dates you last used certain features). When you sync your Device with the Site, we store some of this information.

CHOICES REGARDING YOUR INFORMATION

You have certain choices about how we use your personal information. Certain choices you make are browser and device specific. Note that you will still receive transactional messages from us, including responses to your inquiries. To opt out of receiving our marketing communications, you can follow the instructions contained below.

Cookies

When you use our Site, we gather web traffic information via “cookies”.  Cookies are small pieces of digital information stored by your browser on your computer and tracks initial and returning visits, browsing patterns on our Site, and Products ordered and viewed.  Our cookies do not contain personally identifiable information, but they enable us to identify you as a repeat visitor and help us personalize your numi.com experience.  Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the “Help” section of the toolbar. You need to have cookies enabled on your computer in order to use our Site.  If you do not accept cookies to use our Site, you may not be able to use certain resources or features of our Site. For more information on how to control browser cookies, click here.

Flash Cookies

Certain features of our Site may use locally-stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies, and they are not placed on your computer. You may need to take additional action to manage Flash cookies, which you can learn more about below.

Web Beacons, Pixel Tags, and Third-Party Cookies

NuMi by Nutrisystem or third parties engaged by us, may use web beacons on some pages of this Site.  A web beacon (also known as a pixel tag or clear GIF) is a graphic image which is used to better understand the browsing patterns of visitors to the page.

When the HTML code for the web beacon points to a website to retrieve the pixel image, information can be passed along such as the IP address of the computer that requested the image, the time the web beacon was viewed and for how long, the type of browser that was used, and previously set cookie values.  Web beacons DO NOT pass or read personally identifiable information about you.

Web beacons work in conjunction with cookies set by trusted third parties that are used to assess the effectiveness of particular promotional campaigns or to optimize advertising once a user leaves a website.  View your browser’s help section to determine how to configure your browser to reject or manage first part (i.e., NuMi by Nutrisystem) and/or third-party cookies.  NuMi by Nutrisystem shares aggregated information collected through web beacons to vendors for which the beacon was set to determine the success of marketing campaigns but does not disclose personally identifying information to these vendors.

Third-party ad servers may track anonymous website usage through web beacons on our Site and other websites. They do this by setting a cookie (or reading a cookie previously placed by them) on users’ computers to track the activities of users who view a web page that contains web beacons. Third-party ad servers may use information about your visits to this Site and other websites in order to provide advertisements about goods and services that may be of interest to you. Periodically, upon our request, third-party ad servers may report the anonymous data that they collect on our behalf back to us for our internal use and analysis, and our treatment of this anonymous data is governed by the terms of this Privacy Policy. To learn more about targeted advertising, these providers, or how you may opt out, please visit the Digital Advertising Alliance’s  consumer choice page at http://www.aboutads.info/choices. Technologies other than http cookies may be used by third parties in a similar way, to recognize the email recipient’s computer or device and to keep track of which user identities match to which devices or browsers, and those technologies may not respond to browser settings that block conventional cookies. You may opt out of many of these types of technologies by visiting the National Advertising Initiative’s opt out page at http://www.networkadvertising.org.

Email Tools: You can also change your email settings to block the automatic download of images in email messages, as such images may contain technologies that help us understand how you interact with the message.

How we respond to “DO NOT TRACK” signals

We do not respond to web browser “do not track” signals or other mechanisms that provide you the ability to exercise choice regarding the collection of personal information about your online activities over time and across third-party websites or online services.

We may use cookies and web beacons for insight with respect to the usage of the Site, and so that we could continually improve our customer’s experience.  At times, we use third parties to analyze usage of our Site. However, we do not disclose your personally identifiable information to such third parties.

For more information about our advertising policies, please click here.

 

III. Information We Collect from Third Parties

In addition, we collect personal information about you from third parties in connection with our Services, including from the following sources:

  • Service providers that we engage to perform portions of our Services or provide functionality or features made available through our Site or App.
  • Advertising providers, including online advertising networks and analytics vendors.
  • Social media platforms, including Facebook, FitBit, LinkedIn, Pinterest, Snapchat, TikTok, Twitter, and YouTube.
  • Your contacts or friends who provide your information.
  • Promotional partners.

 

IV. What NuMi by Nutrisystem Does with Your Information

HOW WE USE PERSONAL INFORMATION

Examples of how we may use your information include:

  • To Provide our Products and Services. We may use your information to fulfill your requests for Products or Services and process requests.
  • To Run and Improve our Platform and Business. We may use your information to improve our Products and Services, make our Platform and business better, and to customize your experience with us.
  • To Communicate with You. We may communicate with you about your account, this Privacy Policy, or our Platform terms and conditions.
  • To Verify Your Identity. This includes verifying your identify through other authorization information you provide, for example AppleID and determining your eligibility for our Products and Services.
  • For Marketing Purposes. We may provide you with information about our company, including advertising or providing you with information about Products and offers and sending you communications, including through the mail, email, phone calls, push notifications, or text messages. For more information about your choices related to these communications, see the Choices section below.
  • To Perform Data Analytics. This may include monitoring and analyzing user activity, market research, customer segmentation, financial analysis, and evaluating the effectiveness of our marketing activities.
  • To Respond to Your Requests or Questions. This may include responding to your feedback.
  • For Customer Satisfaction. NuMi by Nutrisystem periodically asks members to participate in online surveys or fill out online questionnaires concerning topics such as the effectiveness of the weight loss program, advertising effectiveness and customer satisfaction. All surveys and questionnaires are optional, and the information collected will not be associated with any user’s personal information. Information gathered may be shared with third parties to improve customer satisfaction and program effectiveness.
  • For Referrals. From time to time, NuMi by Nutrisystem collects third-party email addresses or other contact information from our users and customers so that Nutrisystem may send information to their friends and family on an as-requested basis, such as for referral coupons. We also require the same when users utilize certain functions such as “email this to a friend” features.
  • For Security Purposes. This could include protecting our company and consumers who use our Products and Services, protecting our Platform, or investigating a potential fraud.
  • As Otherwise Permitted by Law or As We May Notify You.

 

How does NuMi by Nutrisystem protect customer information?

Protecting your information from unauthorized disclosure is important to us.  We use the industry standard technology to protect the security of your information.  We have taken certain physical, electronic, contractual and managerial steps designed to safeguard the information we collect from you.  Unfortunately, no data transaction over the Internet can be guaranteed to be 100% secure. We encourage you to use caution when using the Internet. A username and password are needed to access certain areas of the Nutrisystem Platform.  It is your responsibility to protect your username and password.

Will NuMi by Nutrisystem disclose the information it collects to outside parties?

We may share your personally identifiable information in the following ways:

  • Internally. We may share your personal information with our parent company, affiliates and subsidiaries.
  • With Our Service Providers. We may share your personal information with third parties who perform services on our behalf. For example, this may include companies that send emails on our behalf or help us run our Platform.
  • With Our Business Partners. NuMi by Nutrisystem shares your information (other than payment information) with third-party vendors that provide a service for NuMi by Nutrisystem to help us operate our business and our App and the Site and administer activities on our behalf.
  • With Third Parties for Marketing Purposes. NuMi by Nutrisystem may also provide your information and aggregate statistics about our customers, sales, traffic patterns, and related Site information to reputable third-party vendors. This may include the delivery of interest-based advertising, analytics, reporting or strategy. For example, we use Google Analytics, a service provided by Google, Inc., to gather information about how you and other users engage with our Site and Application. For more information about Google Analytics, please visit google.com/policies/privacy/partners. We do not sell your personal information.  However, from time to time, we may make customer e-mail addresses available to other businesses whose products or services might be of value to you. If you do not want us to share your information with other companies or organizations for their marketing purposes, please let us know by opting out here. If you opt-out of promotional or newsletter emails from NuMi by Nutrisystem, we may continue to send you certain communications such as service announcements and administrative messages, relating to NuMi by Nutrisystem that are necessary to our relationship with you. The disclosures in this paragraph do not apply to information obtained through short-code and text messaging, which we do not share, sell, or otherwise make available to third parties. Short-code messaging means SMS messaging via a Nutrisystem short code rather than a nine-digit number.
  • With Any Successors to All or Part of our Business or One of Our Brands. NuMi by Nutrisystem may also sell, transfer or otherwise share some or all of its assets, including your personally identifiable information and non-personally identifiable information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned use or sharing of your information differs materially from that set forth in this Privacy Policy.
  • For Other Reasons We May Describe to You.

In addition to what we have described above, NuMi by Nutrisystem may also disclose your personal information to third parties in certain limited circumstances, as follows:

  1. as necessary if we believe that there has been a violation of our Site Terms and Conditions, of the law, of our rights or of any third party;
  2. to respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and
  3. to share your account information with other members of your household.

Credit Card and Payment Information – Nutrisystem does not share any of your payment information with third parties (except to its payment processors).

Mobile Devices/Third-Party Fees

From time to time, we may make mobile device applications and mobile marketing campaigns available to you and may allow you to register for services that involve push notifications, autodialed text messages, and/or e-mails being sent to your mobile Device. You are responsible for obtaining access to the mobile Device services. Such access may involve third-party fees, including mobile carrier, text messaging, or airtime charges. You are solely responsible for those fees, including any and all fees associated with the use of the applications, delivery of the push notifications, text messages, e-mails or other materials to your mobile Device. Please consult your mobile service provider’s pricing plan prior to purchasing or downloading any application or registering for any such service to determine the charges for sending and receiving push notifications, text messages, and emails from/to your mobile Device. You will be given the opportunity to opt-in to receive push notifications, text messages, or emails to your mobile Device at the time you register for the campaign and with each push notification or email you receive. To stop receiving push notifications or emails from NuMi, please change your communication settings in the NuMi® app and at NuMi.com.  To stop receiving text messages, text “STOP” to our shortcode by responding to any text message received from NuMi.  After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just re-subscribe in the same manner that you previously used to sign up.

If you are experiencing issues with the messaging program you can reply with the keyword HELP for more assistance, or you can get help directly at customerservice@nutrisystem.com or 1-800-585-5483. Carriers are not liable for delayed or undelivered messages.

As always, message and data rates may apply for any messages sent to you from us and to us from you. Message frequency may vary. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.

Mobile marketing campaigns may involve your sending  text message or e-mail from your mobile Device to us or a third-party campaign operator. An autodialed text message, e-mail or other response will then be sent to your mobile Device. Opting to participate in a campaign is 100% your choice.  Your consent to receive marketing text messages is not a condition of any purchase with Nutrisystem, and you may opt out at any time.

When you engage in these mobile marketing campaigns, we and the third-party campaign operator that we work with may collect your cell phone number, the name of your wireless service provider, images that you send using your cell phone as part of the campaign, and other relevant information. We do not share, sell, or otherwise make this information available to third parties.

Our Bulletin Boards, Social Media Pages, Chat Rooms & User Blogs

As part of our Services, we may provide support through bulletin boards, chat rooms (support groups), social media pages, The Leaf and blogs (collectively, “Forums”). Forums give our customers the opportunity to interact with each other. Forums are moderated to help keep inappropriate messages from being posted. You are offered the opportunity to include your email address with your message, but you are not obligated to do so. Please keep in mind that whenever you voluntarily disclose personal information through or on these Forums your information can be viewed, collected and used by others. In short, if you post personal information in a Forum that is accessible to the public, you may receive unsolicited messages from other parties in return. We cannot control the actions of any third parties. By posting any comments, pictures or other information (“Content”) in a Forum hosted by us, you grant us a non-exclusive, irrevocable, royalty-free, perpetual and worldwide right to copy and post both such Content within our Site, and those of our parent, affiliates, subsidiaries, assigns, agents and licensees and any social media outlets and advertising medium through which we are engaged or elsewhere on the Nutrisystem Site, without any further notice to you or any remuneration therefor.

V. Your Rights and Your Consent

A Special Note to Parents or Legal Guardians

NuMi by Nutrisystem only allows the participation of persons 18 years and older to track their weight loss journey on the NuMi App or at numi.com.  For legal guardians or parents of children 14 – 17 years old, please call 1-888-995-3438. For parents interested in helping children younger than 18 to lose weight, please consult a physician. This Site is neither intended for nor directed to children under the age of 14 and we shall not knowingly solicit or collect any personal information from such children.   If you are a parent or legal guardian and think your child under 14 has provided us with personal information, please contact us at  privacy@nutrisystem.com. You can also write to us at the address listed at the end of this Privacy Policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.

 

CALIFORNIA PRIVACY NOTICE

The California Consumer Privacy Act (“CCPA”) requires us to make specific disclosures about how we collect, use, and share the personal information of California residents who are subject to CCPA (“California Consumer Personal Information”). CCPA also grants such California residents certain rights related to their personal information.

This section of our Privacy Policy explains our online and offline collection of California Consumer Personal Information and includes instructions for California residents who wish to exercise their rights under CCPA. Note that this section does not apply to the personal information of California residents that we collect in the employment context or in certain business transactions. This section also does not apply to any information that may be captured by our customers using our Products or Services.

We may collect this category of California Consumer Personal Information.Do we use and share this category of personal information for “business purposes?”Do we use and share this category of personal information for “commercial purposes?”
IdentifiersYESNO
Customer records containing personal information 

YES

 

NO

Characteristics of protected classifications under California or federal law 

YES

 

NO

Commercial informationYESNO
Internet or other electronic network activity information 

YES

 

NO

Geolocation dataYESNO
Audio, electronic, or similar information 

YES

 

NO

Professional or employment-related information 

YES

 

NO

Non-public personal education information 

YES

 

NO

Inferences drawn from the above categories of information to create a profile about preferences 

YES

 

NO

 

  • We collect California Consumer Personal Information as described in Sections 1-3 above, which explains how we obtain personal information.
  • We use the California Consumer Personal Information we collect for “business purposes” and “commercial purposes” as these terms are defined in CCPA. These purposes are as described in the “HOW WE USE PERSONAL INFORMATION” section of this Privacy Policy.
  • We share California Consumer Personal Information we collect with third parties as described in the “HOW WE SHARE PERSONAL INFORMATION” section of this Privacy Policy. However, as of the date of this Policy, we do not knowingly “sell” California Consumer Personal Information. This statement is based on our understanding of how the term “sell” is defined under CCPA as of the date of this Privacy

California Residents Rights under CCPA. Subject to certain exclusions, the CCPA allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information give consumers the following:

  • The right to request the following information regarding our use of your California Consumer Personal Information:
    • The categories of your Personal Information that we have collected
    • The purposes for which we have collected or used such California Consumer Personal Information
    • The categories of sources for the California Consumer Personal Information we have collected about you
    • The categories of third parties with whom we have disclosed your California Consumer Personal Information
    • If we have disclosed your California Consumer Personal Information for a business purpose, a list identifying the California Consumer Personal Information categories that each category of recipient obtained
    • If we have sold your personal information, a list identifying the California Consumer Personal Information categories that each category of recipient purchased
  • The right to receive a copy of your California Consumer Personal Information
  • The right to request us to erase your California Consumer Personal Information when we no longer need such data in connection with our Services (subject to certain exceptions that may apply under applicable law).
  • The right to equal rights and services. This means that we are prohibited from discriminating against you if you exercise your rights under CCPA.

In compliance with CCPA, we maintain records of consumers for at least 24 months.  This information is maintained for record-keeping purposes and is not used for any other purpose except as reasonably necessary for us to review and modify our processes for compliance with CCPA.

* California Residents who  wish to exercise any such rights listed above, please contact us by either:

  • Phone: 1-888-914-9661 PIN:898901

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your California Consumer Personal Information. Please understand that we are required to verify your request and may require you to provide some information to enable us to carry out such verification. We cannot respond to your request or provide you with California Consumer Personal Information if we cannot verify your identity or authority to make the request and confirm the California Consumer Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use California Consumer Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

California’s “Shine the Light” law. California’s Civil Code section 1798.83 requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third-party businesses for the third-party businesses’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third-party businesses for the third party businesses’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As discussed above, if you wish to opt-out of our sharing of your information with third-party businesses for the third-party businesses’ direct marketing purposes please opt out here. You can also make a request, by sending us an email at privacy@nutrisystem.com or writing to us at the address listed below. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry.

NEVADA PRIVACY NOTICE

If you are a Nevada resident, under Privacy and Security of Personal Information Chapter of the Nevada Revised Statutes Section 603A (603A), you have the right to submit a verified request to us, directing us not to make any sale of certain personal information that we have collected or will collect about you. As of the date of this Privacy Policy, we do not knowingly engage in the sale of personal information of Nevada residents. This statement is based on our understanding of how the term sale is defined under 603A as of the date of this Privacy Policy. However, Nevada residents who wish to exercise their rights under this section can email us at privacy@nutrisystem.com. Please indicate you are a Nevada resident making a “Nevada Opt-Out” request.

Your Consent and Notification of Change

By using our App and/or Site you consent to the collection and use of your information by NuMi by Nutrisystem. If you do not want to receive additional promotions from us, please let us know by opting out here.   If you do not agree to the terms of this Privacy Policy, you should not use our App or Site.

If at some point in the future, there is a change to our information usage practices that affect your personally identifiable information, we will notify you by e-mail or by posting the change on our Site, depending on the change. Accordingly, you should check this posted Privacy Policy for changes. All amended terms automatically take effect 30 days after they are posted.  Also, depending on the nature of the change, you may have the option to opt-out of the new information usage by opting out here. You should check this posted Privacy Policy for changes.

If you want to subscribe to our e-newsletter, we only require your e-mail address.  You may unsubscribe at any time by following the opt-out directions in the newsletter or by clicking here.

If you opt-out of promotional or newsletter emails from NuMi by Nutrisystem, we may continue to send you certain transactional communications, such as service announcements and administrative messages relating to your account with us that are necessary to our relationship with you.

Corrections/Updates

To make changes to any of your personal information, you can log into your account and click in the Personal Information section of the NuMi® App or on My.NuMi.com or call Nutrisystem at 1-900-585-5483.   To change any of your account settings, you can log into your account and click in the Account Settings section of the NuMi App or on My.NuMi.com. Household members may not make changes to your account information or cancel your account without your express permission. If you have not already indicated your permission for household members to access your account at the time you placed your first order, please call 1-877-338-8446.

 

VI. Third-Party Websites

Links

Our App and/or Site may contain links to third-party websites, which may have privacy policies that differ from our own. If you click on a link to a third-party site, you will be taken to a site we do not control. We are not responsible for the activities and practices that take place on these sites. Accordingly, we recommend that you review the privacy policy posted on any site that you may access through our App and/or Site.

Storage of Information

Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. This Platform is intended for use in the United States and is subject to the laws of the United States, which may not provide the same level of protections as those in your own country.

VII. Tell Us What You Think

If you have questions, comments or concerns with respect to our privacy practices or this Privacy Policy, or with to update your information, please feel free to contact us at privacy@nutrisystem.com. You may also write to us at the following address:

 

Nutrisystem, Inc.
600 W Office Center Dr.
Fort Washington, PA 19034
Re: Numi’s Privacy policy

 

Terms and Conditions

Please also read the Terms and Conditions on the Site to understand additional terms and conditions which apply to the use of our App and/or Site.

Privacy Policy last updated April 29, 2021