ARTICLE 1 OBJECT

The purpose of these general terms of use (hereinafter referred to as CGU) and this confidentiality policy is to define the conditions of use of the website www.parisfranceparking.fr, which is the property of PARIS FRANCE GARAGE, a simplified joint-stock company with a capital of 7,067,136 whose registered office is 211 Avenue Gambetta, 75020 Paris, registered in the Paris Trade and Companies Register under number 602 013 518 (Intra-community VAT number: FR88 602 013 518) (hereinafter "Paris France Parking") and establish the conditions under which, Paris France Parking or its subsidiaries market parking offers. They also govern the conditions relating the access of car parks, the reservation process and the pricing rules in force.

These conditions and privacy policy are accessible at the URL https://www.parisfranceparking.com/privacy-policy.html or by clicking on the hypertext link at the bottom of the "contact / reservation" page (I accept the General Conditions)

ARTICLE 2 DEFINITIONS

"Site" means the online booking website www.parisfranceparking.com

"User / Customer" means any user of the Site who takes cognizance of the information and / or reserves a Service offered on the Site.

"Service" means all the services marketed by the car park.

"Parking" means the parking lot in which the customer will park his vehicle.

"Internet rate" means the advantageous rate applied to parking formulas, the duration of which is defined at the time of booking. This rate, valid only for the selected parking period and for the date indicated, is only applied if the customer presents himself to the attendant within one hour of his arrival at the car park, provided with a reservation code.

"Package" means the countermark given to the Customer when the latter pays the amount of the chosen parking time upon arrival at the car park. This countermark allows the customer multiple entries / exits from the car park during the entire paid parking period.

"No reservation" rate means the parking rate applied to parking plans for defined periods, without the customer having made a prior reservation.

"Monthly subscription" means all the parking formulas implying a subscription subject to a commitment period of a minimum period of 6 months.

"Agent" means the agent present at the reception of the car park authorized to make collections.

"Utility" rate indicates the rate grid specifically dedicated to the vehicle category whose height is greater than the limit authorized in each car park, for passenger vehicles.

"Means of access" means the means made available to the User to unlock pedestrian access, enter and exit the car park through the car park terminals. The means of access are, parking tickets, packages or vouchers, access cards or automatic opening by recognition of license plate.

ARTICLE 3 COMPLIANCE WITH THE TERMS AND CONDITIONS AND THE PRIVACY POLICY

Access to the Site by the User signifies his acceptance of these terms of use and privacy policy. Any reservation request submitted on the Site implies acceptance without any reservation or restriction of these by the customer.

When booking on the site via the Contact / Reservation Form, each user expressly accepts these presents by checking the box preceding the following text: "I accept the General Conditions of Use, the General Conditions of Sale, the legal notices and the Paris France Parking Privacy Policy .

The Site www.parisfranceparking.com reserves the right to modify unilaterally and at any time the content of these Terms of use and privacy policies.

ARTICLE 4 RESPONSIBILITY OF THE EDITOR

The information and / or documents appearing on this site and / or accessible by this site come from sources considered reliable.

However, this information and / or documents may contain technical inaccuracies and typographical errors.

Paris France Parking reserves the right to correct them as soon as these errors are brought to its attention.

It is strongly recommended to check the accuracy and relevance of the information and / or documents made available on this site.

ARTICLE 5 CAPACITY

The services are accessible to any User who is at least 18 years old and has full legal capacity to contract and use the Site in accordance with these conditions, provided they have a computer, tablet or a smartphone and an internet connection. The User is responsible for all actions carried out on the Site.

ARTICLE 6 OBJECT OF THE SITE

The www.parisfranceparking.com site references the parking lots of Paris France Parking and its subsidiaries. The Site allows the User to obtain all the information relating to the location of the car parks, the accessibility conditions and the rates charged according to the different parking formulas marketed. The Site also makes it possible to reserve a parking space for a fixed period.

Special cases for the Place des Fêtes and Bellefond car parks:

It is specified that the company Paris France Parking acts as a simple intermediary on behalf of these two car parks. Users do not contract directly with the company Paris France Parking for the parking formulas sold in the Place des Fêtes and Bellefond car parks. The user contracts with the company Parking Paris Nord (8 rue Compans, 75019 Paris) for the Place Des Fêtes parking lot and with the company STIF (10 rue de Bellefond 75009 Paris) for the Bellefond parking lot.

These two companies are subsidiaries of Paris France Parking.

Paris France Parking is happy to inform users about the pricing and accessibility conditions applied by these establishments and offers to reserve a free parking space on the Site, benefiting from a preferential rate.

In the event of disputes or complaints addressed concerning the Place des Fêtes and Bellefond car park, Paris France Parking undertakes to transmit them as soon as possible to the companies concerned. It is specified that the responsibility of Paris France Parking, a simple technical intermediary, may in no case be engaged in the event of non-performance or poor performance of the contractual obligations attributable to the above-mentioned car parks.

It is recalled that any reservation made on the Site legally commits the company operating the Parking directly to the User and the User vis-à-vis the company operating the Parking. The operating company is therefore solely responsible for the proper performance of the parking services (and its associated services) provided.

ARTICLE 7 RESERVATION (except utility space cf. Article 12)

The reservation of parking space on the Site is completely free.

The reservation allows the User to benefit from a preferential rate, which will be granted directly upon arrival at the car park, upon simple presentation of the confirmation received by email and containing the reservation code.

The user wishing to book on the Site must therefore have an email address for sending the booking confirmation by email.

The customer makes a reservation by clicking on the "contact / reservation" tab on the top banner of the Site. He must then fill in the required information on the dedicated form and check the box relating to the collection of consent as indicated in Article 3.

Reservation is also offered when the User searches from the home page. In this case, the Customer indicates:

- firstly, a precise postal address and the expected date of arrival

- in a second page, he selects the vehicle category and clicks on "search"

- in a third page, it provides the desired parking time and clicks on "search"

The customer is then redirected to a page displaying, as a result, the nearest geographically located car park by public transport, from the destination indicated on the home page.

He can then choose to click on the "book" button and is redirected to the page containing the booking form.

Finally, he can also book directly by accessing the parking form from the top banner of the site. On this page, you will find the parking location information, the rates charged and a "book" button allowing the customer to be redirected to the booking form.

As soon as the reservation is made, the Customer receives an email containing a reservation code which allows him to benefit from a preferential rate, to the email address he has entered.

The User can also simply inquire on the Site about the various Services offered without making a reservation. In this case, he will not be able to benefit from "internet rates".

ARTICLE 8 OPERATION (except utility space cf. article 12)

1 / Access to the park

a) Access with reservation

Once arrived at the car park (the day of his reservation), the customer will collect a ticket at the entrance terminal and park his vehicle (except utility space see Article 12). Then, they will come to reception to provide the attendant with the reservation code and make the payment for the parking time indicated in the confirmation email received.

Once the payment has been made, the attendant will provide him with a countermark which will be used to open pedestrian access and enter and exit the Parking lot for the duration of his stay.

If the customer is unable to show the attendant the proof of his reservation, he will not be able to benefit from the internet rates and will have to pay the parking fee displayed at the entrance to the Parking lot.

When he leaves, and if he has not passed the scheduled exit time, he just has to insert his countermark in the exit terminal to leave the Parking.

Users are recommended to keep their voucher, which is essential for entering and leaving the Parking, carefully.

In the event of loss of the countermark, the attendant will make no barrier opening and no exit ticket may be given to the User, who must pay the parking duration at the rate in effect in the Parking.

If the authorized exit deadline is exceeded, the Customer will be billed for the duration of the overrun according to the price list in force in the Car Park. Any time slot started is due. It is specified that the payment at the quarter of hour applies only for the first twelve hours of overtaking. Beyond that, the daily rate is applied.

b) Access without reservation

b.1 - Once arrived at the car park, the customer will collect a ticket at the entrance terminal and park their vehicle. Then, if the customer wishes to enter and leave his vehicle during his stay, he can go to reception to make full payment for the chosen parking time in order to obtain the appropriate countermark.

When he leaves, and if he has not exceeded the scheduled exit time, he just has to insert his countermark in the exit terminal to leave the Parking.

Users are recommended to keep their voucher, which is essential for entering and leaving the Parking, carefully.

In the event of loss of the countermark, the attendant will make no barrier opening and no exit ticket may be given to the User, who must pay the parking duration at the rate in effect in the Parking.

If the authorized exit deadline is exceeded, the Customer will be billed for the duration of the overrun according to the price list in force in the Car Park. Any time slot started is due. It is specified that the payment at the ¼ hour only applies for the first twelve hours of excess. Beyond that, the daily rate is applied.

b.2 - If the customer does not need to use his vehicle during the parking period, he is not required to pay for his parking in advance. He can pay the parking fee when leaving the car park. Any time slot started is due. It is specified that the payment at the ¼ hour only applies for the first twelve hours of parking. Beyond that, the daily rate is applied. Then, beyond that, any new day started is due in full.

2 / Obligations

By entering the Car Park, the Customer unreservedly agrees to comply with the internal regulations displayed in the car parks and in particular:

- to respect the rules of the highway code. As such, the Customer ensures that he holds a driving license valid in France and corresponding to the category of vehicle used

- to respect the specific height limitations in each car park

- to park a vehicle duly insured and certified as a driver, also to be covered by an insurance policy valid for the entire effective duration of parking in the Parking

- to respect the limitations of parking spaces, taking care not to encroach on the markings on the ground.

- to refrain from maintaining his vehicle inside the Car Park, or to carry out any repair of the latter.

- park and immobilize your vehicle for more than 90 days

Parking is at the User's own risk. The fee paid by the Customer does not constitute a right of custody or a right of surveillance of the vehicle.

ARTICLE 9 SUBSCRIPTION

Subscriptions are carried out exclusively in situ.

The User can collect information relating to the subscription methods and reserve a parking space on the Site. However, to finalize the subscription, the User must go to the Parking lot to sign the rental commitment and pay the first rental invoice including the pro rata of the current month, the security deposit and the fee linked to access. As soon as these administrative formalities are completed, the customer is given a means of access to enter and exit the parking lot for the duration of the contract.

Subscription contracts automatically include minimum commitment periods ranging from 6 to 12 months, depending on the subscription plans purchased.

Subscription contracts can be terminated at the end of the commitment period. The user must send a registered letter with acknowledgment of receipt, respecting a full month's notice.

The subscription methods are shown on the subscription form that the User can collect at the reception of the car parks or by requesting it by email, at the address: info@parisfranceparking.fr

The general conditions of the Subscription contract are also available on request at the address: info@parisfranceparking.fr

ARTICLE 10 CANCELLATION (except utility space cf. article 12)

As the reservation is free, the User can cancel the reservation made at any time and at no cost, by simply clicking on the "cancel" button in the confirmation email received after validation of the reservation form.

ARTICLE 11 FINANCIAL CONDITIONS AND PAYMENT METHOD

11.1 Rates

The Rates indicated on the Website are in Euros, all taxes included.

Rates vary according to the parking formulas marketed and the car parks referenced on the Site.

Paris France Parking reserves the right to modify prices at any time and without notice, but the price applicable to the reservation will remain that indicated in the reservation confirmation and will be the price which will be granted to the User when paying at the car park.

11.2 Payment

a) The parking fee is paid in full upon payment made by the User upon arrival at the Parking for Customers wishing to obtain a Package or before leaving the Parking for Customers who have not purchased Packages on their arrival.

The payments are made by Credit card (Visa - Mastercard - Total GR) or in cash for parking formulas not subject to commitment.

b) Monthly subscriptions with a commitment period are payable in advance, by check, Credit card (Visa - Mastercard), cash or Sepa direct debit. For Bellefond Parking, only payments by checks or Sepa direct debit are accepted.

The User cannot claim any reimbursement if he leaves the Parking before the end of the parking period paid upon his arrival.

When the Customer buys a Pass upon arrival at the Parking, he cannot ask to extend the initial parking period, he will have to pay the excess at the hourly rate in force in the parking lot.

ARTICLE 12 UTILITARY AREA

Unlike private vehicles, the rental of parking spaces for commercial vehicles is subject to a compulsory prior reservation. The parking of a utility vehicle results in an overnight rate (arrivals are possible from 12 noon and the final exit must be made before 12 noon on the day of departure).

We have covered underground parking spaces in our Pyrénées-du Clos car park, capable of accommodating utility vehicles up to 2.80m in height.

Covered spaces are also available at the Place des Fêtes car park for vehicles not exceeding 2.25 m in height.

Finally, open parking spaces can accommodate utility vehicles over 2.80m high in our Gambetta car park, without however exceeding 7m in length.

The reservation of the pitch is also free and allows the User to receive a confirmation voucher by email.

If the User is a Private Customer, payment will be made in situ upon arrival at the Parking. The User, Private Client can withdraw at any time, before the start of the service, without penalties, by sending a simple email to the address: info@parisfranceparking.fr

ARTICLE 13 IMPOSSIBILITY FOR THE PARKING TO PROVIDE THE RESERVED SERVICE AND FORCE MAJEURE

In the event that the Car Park is unable to provide the Customer with the reserved service, the User will be informed as soon as possible by e-mail or telephone.

As part of its customer relations policy, Paris France parking will endeavor to offer the Customer an equivalent replacement parking solution in the other available car parks.

Parking cannot be held liable if the non-performance or the delay in the execution of one of its obligations described in these Terms of Use and Privacy Policy, is the result of a case of force majeure as provided for in articles 1351 and 1351-1 of the Civil Code.

ARTICLE 14 UNABLE TO ACCESS THE SITE

The company Paris France Parking will make every effort so that the User can access the Site at any time and without interruptions.

However, the Site may be subject to maintenance in order to correct anomalies or bugs, update information and in general to perform any technical operation making the Site inaccessible to the User.

In this case, the User will be informed of the interruption of the Site by an error message.

However, Paris France Parking cannot be held liable for damages of any kind whatsoever including in particular the loss of profits or the loss of chance, which could result from the total or partial impossibility of using the functionalities of the Site.

In no event Paris France Parking can not be held responsible for errors arising from a failure of the User's connection to the site.

ARTICLE 15 COMPLAINTS

Any request for information, clarification and any complaints must be sent via the complaint form available at the reception of the car parks or at the following address: info@parisfranceparking.fr

Any complaint must be made in writing at the latest 15 days after the event which justifies it.

ARTICLE 16 APPLICABLE LAW

In case of dispute and lack of prior agreement, the competent court is the Paris Court.

ARTICLE 17 MEDIATION

According to article L211-3 of the Consumer Code, the Customer may have recourse to the possibility of carrying out a conventional mediation action if a misunderstanding or disagreement persists.

After having exhausted the amicable means of recourse by means of a complaint, the User will be able to address himself free of charge to the Mediator of consumption of which we are responsible and whose contact details are available at http://www.mediateur-cnpa.fr/ within a period of less than one year from the date of his complaint.

ARTICLE 18 INTELLECTUAL PROPERTY

Access to the Site does not confer any right on the intellectual property rights of this Site, which remains the exclusive property of PARIS FRANCE GARAGE.

In application of the French Code of Intellectual Property and more generally, treaties and international agreements containing provisions relating to the protection of copyright, you may not reproduce for a use other than private, sell, distribute, broadcast, broadcast , transform, publish, communicate in whole or in part, in any form whatsoever, the data, presentation or structure of the site or the works protected by copyright which appear on the website https://www.parisfranceparking.com without specific prior written authorization from the copyright holder attached to the work, the presentation or the structure of the site or the data reproduced.

The general structure, as well as the texts and images composing this site are the property of PARIS FRANCE PARKING.

The reproduction and use of all documents published on this site are exclusively authorized for strictly private, non-commercial purposes, and subject to acknowledgment of the source. Any reproduction, use or distribution of copies made for other purposes is expressly prohibited and penalized.

No hypertext link to our sites can be implemented without the express prior written agreement of PARIS FRANCE PARKING.

The https://www.parisfranceparking.com site is governed by French law. Visitors with access to the site from abroad must ensure compliance with locally applicable laws.

The site, operated by PARIS FRANCE PARKING has been regularly declared to the CNIL, under the number: 1672132

Introduction

We place great importance on protecting and respecting your privacy and we are committed to ensure the privacy of the personal data we collect.

Personal data collected is for internal use only.
We commit not to sell your personal data to any third parties.

This policy is intended to inform you of our practices regarding the collection, use and sharing of information that you are required to provide us through through our website https://www.parisfranceparking.com or handwritten subscription forms in our parking.

Forms and interactivity

Your personal information is collected by means of forms, ie, booking form or contact form, but also handwritten forms in our reception offices.
We use the collected information for the following purposes:

• Follow-up of the request or reservation
• Subscription
• Contact
• Statistics
• Correspondence

Collection of personal information

How do we collect your data?

We collect your personal data in 2 ways:
- When you fill out a booking or contact form on our website
- When you voluntarily complete a subscription form for a long-term subscription contract voluntarily and in writing. These forms are then given to a parking attendant

What personal information do we collect?

The information collected is as follows:

- Reservation form or contact form on our contact/ booking page

• Type of reservation (by the hour / by the day or by the long term)
• Vehicle type (height)
• Expected arrival date
• Planned parking time
• Selected parking
• E-mail adress
• Landline and / or mobile phone number: this information is optional
• Vehicle registration (only for commercial vehicles over 1.95m high)

We also use, as indicated in the next section, log files or cookies to gather information about you.

- Subscription form for a long-term subscription contract in the car park:

• Name
• First Name
• Address
• Postal code
• Email address
• Fixed telephone number and / or mobile phone
• Vehicle model
• Vehicle registration
• Bank details (IBAN for customers who have opted for SEPA direct debits)

Purpose of collecting your personal data

Personal data collected using the forms described in the previous section have a specific purpose.

What are your personal data collected for?

CASE N ° 1: Reservation form or contact form on our contact page

• Type of reservation (hourly / daily or long term subscription): you indicate in this section the length of stay that you want, which allows you to reserve the right parking
• Vehicle type (height): we need to know the height of your vehicle to direct you to the appropriate parking lot, given the different heights of the ceilings of our car parks
• Expected arrival date: to reserve a place on the desired date
• Expected parking time: to reserve a place for the desired duration
• Parking selected: to reserve a place in the desired parking lot
• Email address: to send you a booking confirmation or to answer your request for information
• Phone number - this information is optional this information allows us to contact you in case a problem appears in your booking or to your vehicule
• Registration of the vehicle (only requested for vehicles over 1.95m high): to be able to identify vehicle since spaces for utility vehicles are very limited

CASE N°2 Subscription form in our parking:

• Name / Surname: this data allows us to identify you and generate your subscription contract in our commercial management software
• Postal address / postal code: to allow us to send you information / reminder letters and / or your invoices
• E-mail address: to allow us to send you information / reminder letters and / or invoices in electronic format
• Telephone and / or mobile phone number This information is optional and allows us to contact you in case of emergency or to give you information about your subscription contract.
• Vehicle model / vehicle registration: to attach the vehicle that will be parked in our car parks to your subscription contract and thus allow us to ensure safety and control fraud
• Bank details (IBAN for customers who have opted for payment by SEPA direct debit): your bank details appearing on the SEPA direct debit mandate that you sign authorizes us to deduct from your bank account the sum corresponding to the payment of your monthly subscription

Log and cookie files

We collect certain information through log files and cookies.
This is mainly the following information:

• Operating system
• Visited pages and queries
• Time and day of connection

The use of such files allows us to:

• Improve service quality and a personalized experience
• Statistics

Underage

Our site is only intended for Major Users. Use by minors is not allowed.

External link

Links to other websites are available from our site. If you use these links, you leave the PARIS FRANCE PARKING website. These third party sites have not been checked by us. We are in no way responsible for the content and / or privacy policy of the personal data of these other sites.
PARIS FRANCE PARKING neither endorses nor approves the content to which these sites or sources give access, and excludes all liability and guarantee with regard to these contents. If you decide to access these sites, you do so under your sole responsibility. We invite you to read the privacy policies of these sites before transmitting your personal data.

Google Maps / Opinion

Certain parts of our Website use the Google Maps and Google Avis mapping services. Use of Google Maps / Avis is subject to the Google Maps / Avis Additional Terms of Service and Google Privacy Policy.

Opinion

We publish the opinions you write as part of our notice system on our website. These notices, which may contain your first name and / or your name, are visible to all visitors on our website. You may object to this at the time of collection or at any time thereafter, as mentioned in the following section.

Targeted advertising

In accordance with applicable law and with your consent when required, we may use the data you provide to us to display targeted advertising on social media platforms (Facebook). On social media platforms, you can object to this processing at any time by configuring the advertising parameters of your account.

Your agreement to these conditions

By using the PARIS FRANCE PARKING website, you signify your agreement to this privacy policy.

Cookies

Different types of cookies are used on our website:
- Cookies strictly necessary for the provision of the service requested by the user (hereinafter "category 1").
- Social network cookies, audience measurement cookies and behavioral analysis cookies (hereinafter "category 2").

On this site, we find the following types of cookies:

Consent to the use of cookies

When you go to our website you go to the Paris France Parking homepage. If you continue browsing without setting up cookies, you accept the use of cookies. Your consent to the deposit of cookies is valid for a maximum of twelve months.
You can always return to your choice and set, delete or block all or part of the cookies on the site or application. To do this, click on the "Learn More" link located at the bottom of each page of the site or application to access this page and follow the instructions below.

Refusal / blocking of cookies

You can block the use of all or part of the cookies by setting your browser.
Depending on the browser you are using, follow the instructions below to set the cookies.

Refusal / blocking of cookies

Storage period of your data

Your personal data are kept for 12 months:
- after your last booking on our website
- after the date of termination of your subscription contract

These data are then transferred to an encrypted file accessible only to the DPO (Data Protection Officer) and accessible by order of the President in case of administrative need, particularly in case of litigation, justifying keeping them for the time of the applicable prescription / foreclosure rules, especially in commercial, civil and fiscal matters.

Right of opposition and withdrawal

We are committed to providing you with a right to object, rectify and opt out of your personal information.
The right of opposition is understood as the possibility offered to Internet users to refuse that their personal information be used for certain purposes mentioned during the collection.
The right of rectification means the possibility of asking us to correct inaccurate or incomplete personal information about you.
The right of withdrawal is understood as the possibility offered to users to request the deletion of their personal data so that their personal information no longer appear, for example, in a mailing list.
To exercise these rights, you can write to us at:
PARIS FRANCE PARKING : 211 AVENUE GAMBETTA, 75020 PARIS
Email: privacy@parisfranceparking.fr
Phone: +331 44 64 90 60
Website section: https://www.parisfranceparking.com/privacy-policy

Commercial prospecting by telephone

According to article L223-1 of the Consumer Code, the User who does not wish to be the subject of commercial prospecting by telephone can register for free on a list of opposition to canvassing. It is prohibited for a professional, directly or through a third party acting on his behalf, to contact a consumer registered on this list by telephone, except in the case of pre-existing contractual relationships.

Permission to Access

We are committed to recognizing a right of access and rectification to data subjects wishing to consult, modify or delete information concerning them.
The exercise of this right will be done:
by mail to: PARIS FRANCE PARKING : 211 AVENUE GAMBETTA, 75020 PARIS
by email: privacy@parisfranceparking.fr
Phone: +331 44 64 90 60
Website section: https://www.parisfranceparking.com/privacy-policy

Security

The personal information we collect is kept in a secure environment. People working for us are required to respect the confidentiality of your information.
To ensure the security of your personal information, we use the following measures:

• Secure Sockets Layer (SSL) protocol
• Access Management - Authorized Person
• Firewalls
• Encryption

We are committed to maintaining a high degree of confidentiality by incorporating the latest technological innovations to ensure the confidentiality of your transactions. However, since no mechanism offers maximum security, there is always a risk involved when using the Internet to transmit personal information.
The data collected by hand is stored in a secure environment, accessible only by our authorized staff. They are destroyed within the deadlines indicated in the section above

Access control

An access control device to control access to the car park has been set up by PARIS FRANCE PARKING.
Only authorized persons (administrative service, park manager, technical manager) will have access to your personal data.
In accordance with the law "IT and freedoms", you have a right to access and rectify data concerning you which will be kept 1 year after the end of the subscription contract.
You can access your information by contacting:
PARIS FRANCE PARKING
Data protection service
211 avenue Gambetta 75020 PARIS
privacy@parisfranceparking.fr
+331 44 64 90 60

LAPI

Our parking lots have a computerized access control system of the LAPI type (automatic reading of license plates), reserved for the use of its authorized personnel, to enable them to manage and control access to the parking.

Our parking lots have a computerized access control system of the LAPI type (automatic reading of license plates), reserved for the use of its authorized personnel, to enable them to manage and control access to the parking.

Sharing of Personal Information

We undertake never to market the personal information collected. However, we sometimes share this information with third parties if we need to have a task performed by a third party maintenance service.

In addition, your data can be transmitted punctually in the event of an order from a state service.

Legislation

Version of the Terms of Use and the Privacy Policy