Privacy Policy

Your Data Matters

We prioritize safeguarding your personal information and ensuring your online privacy.

DRCFO MANAGEMENT CONSULTANTS PRIVATE LIMITED (hereinafter the “Company”, “We”, “Us”, and “Our” interchangeably) is the owner of the Website www.drcfo.in and the Mobile Application (hereinafter “Application” which includes the Website, Software program, data and documentation related thereto), and provides services related to health data management, online appointments with healthcare professional, Clinic management, Clinic administration, Patient Management, Accounts & Inventory management along with Legal compliance management and other related services (collectively referred to as “Service/Services”) for integrated health care management for patients and healthcare professionals. This Privacy Policy must be read in conjunction with the Terms of Use. Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms of Use. We are committed to Your privacy. This privacy policy (“Privacy Policy”) applies to Your use of and access to the Services and the collection, use, storage, sharing, processing, disclosure, and transfer of Your Information including Your Personal Information when You access and/or use the Services. You are advised to carefully read this Privacy Policy before using or accessing any of Our Services. Our Privacy Policy is applicable to every User who accesses our Application and/or uses Our Services (referred to as “You”, “User” or “Your” as applicable) from any device.

1. CONSENT

1.1 By using the Services or by otherwise voluntarily providing us Your information, You will be deemed to have read, understood, and agreed to the practices and policies outlined in this Privacy Policy and agree to be bound by the same.
1.2 You acknowledge that You are providing Your Personal Information out of Your free will.
1.3 You hereby consent to Our collection, use and sharing, storage, processing, and disclosure of Your information as described in this Privacy Policy.
1.4 If You use the services on behalf of someone else, You represent that You are authorized on behalf of such User by such User to accept this Privacy Policy, and consent to Our collection, use, and disclosure of such information as described in this Privacy Policy.
1.5 We reserve the right to amend the portions of terms of this Privacy Policy by way of modification, addition, or deletion, at Our sole discretion, at any time. The last updated date on the top of the page indicates when the Privacy Policy was last updated. If you do not agree to the amendments in this Privacy Policy at any time, do not use any of the Services any further.
1.6 You have the option not to provide Us the Personal Information. You also have the option to withdraw Your consent at any point. If You do not provide us with Your Personal Information or if You withdraw the consent at any point in time, You shall not be able to access and use Our Services.

2. SCOPE

This Privacy Policy states the type of information collected from the Users, the purpose, means, and modes of collection, usage, processing, retention, and destruction of such information; and how and to whom We will disclose such information.

3. COLLECTION OF PERSONAL INFORMATION

3.1 We may ask You to voluntarily provide Us with certain information that personally identifies You or could be used to personally identify You. You hereby consent to the collection of such Information by Us.
3.2 Without prejudice to the generality of the above, Personal Information collected by Us for Your registration to Our Services may include (but is not limited to) the following:

3.2.1 Name
3.2.2 Date of Birth
3.2.3 Email address
3.2.4 Phone Number
3.2.5 Gender
3.2.6 Location
3.2.7 Pin code

3.3 Without prejudice, to make full use of Our Services and best meet Your needs, Information collected by Us may include (but is not limited to) the following:

3.3.1 data regarding your usage of the services and history of the appointments made by or with You through the use of Services
3.3.2 sensitive financial information such as bank accounts, credit, and debit card details, or other payment instrument details;
3.3.3 biometric information
3.3.4 medical records and history
3.3.5 physical, physiological, and mental health conditions
3.3.6 other information that You voluntarily choose to provide to Us

3.4 We shall be free to use, collect and disclose information that is freely available in the public domain without your consent.
3.5 We may also seek permission to use the camera, microphone, and phonebook/contact data at points where required.
3.6 We may also collect information other than Personal Information from You when You visit and /or use the Application. Such information may be stored in server logs. Such Non-Personal Information would not assist us to identify You personally. Such Non-Personal Information may include

3.7.1 Your usage details such as time, frequency, duration and pattern of use, features used and the amount of storage used,
3.7.2 Master and transaction data and other data stored in Your user account,
3.7.3 Internet Protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system, and other visitor details collected in Our log files.

3.8 We automatically enable the listing of Subscribed User’s information on our Application for every Practitioner availing Our Services. The Subscribed User Information listed on Our Application is displayed when the User searches for Practitioners on the Application, and the Subscribed User Information listed on Our Application is used by the User to request for appointments. Any Personal Information of the Subscribed User listed on the Application is not generated by Us and is provided to Us by Subscribed Users who wish to enlist themselves as Practitioners on Our Application. We display such information on Our Application on an as-is basis making no representation or warranty on the accuracy or completeness of the information. As such, we strongly encourage Practitioners to check the accuracy and completeness of their information from time to time and inform Us immediately of any discrepancies, changes, or updates to such information. We will, however, take reasonable steps to ensure the accuracy and completeness of this information.

4. METHODS TO COLLECT INFORMATION

4.1 The methods by which We collect Your Information include (but are not limited to) the following:

4.1.1 when You register on Our Application;
4.1.2 when You create a profile on Our Application or as part of Services;
4.1.3 when You provide Your Information to us;
4.1.4 when You use the features on Our Application and/or when You use Services;
4.1.5 when You access Applications or Services;
4.1.6 by use of cookies

5. USE OF THE COLLECTED INFORMATION

5.1 We collect Your Information for various purposes, an indicative non-limiting list of such purposes is mentioned below:

5.1.1 in order to enable You to use the Application and utilize the Services. For instance, you may provide Your health-related information on the Website in order to consult privately with a Practitioner, or You may provide Your financial information in order to process a payment which You need to make on the Application;
5.1.2 to respond to Your inquiries;
5.1.3 to provide You with information about products and services available on the Application;
5.1.4 to personalize Your experience on the Application;
5.1.5 to help You address Your problems incurred on the Application including addressing any technical problems;
5.1.6 for proper administering of the Application;
5.1.7 to conduct internal reviews and data analysis for the Application (e.g., to determine the number of visitors to specific pages within the Website);
5.1.8 to improve the services, content, and advertising on the Application;
5.1.9 to protect the integrity of the Application;
5.1.10 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;
5.1.11 to conduct analytical studies on various aspects including User behavior, User preferences, etc;
5.1.12 analyzing anonymized practice information for commercial use;
5.1.13 processing payment instructions including those through independent third-party service providers such as payment gateways, banking, and financial institutions, pre-paid instrument and wallet providers for the processing of payment transactions or deferral of payment facilities;
5.1.14 analyzing software usage patterns for improving the utility of Our Services;
5.1.15 for communication purposes so as to provide You with a better way of booking appointments and for obtaining feedback in relation to the Practitioners and their practice;
5.1.16 debugging customer support-related issues;
5.1.17 for the purpose of contacting You to complete any transaction if You do not complete a transaction after having provided Us with Your contact information in the course of completing such steps that are designed for the completion of the transaction;
5.1.18 to make disclosures as may be required under applicable law.

6. ACCURACY AND UPDATION OF YOUR INFORMATION

6.1 You are responsible for maintaining the accuracy of the information You submit to Us, such as Your contact information provided as part of account registration.
6.2 If your Personal Information changes, You may correct, delete inaccuracies, or amend information by making the change in Your profile and informing us at the email provided below or using the Contact Us option.
6.3 We will make good faith efforts to make requested changes in Our then active databases as soon as reasonably practicable.
6.4 If You provide any information that is untrue, inaccurate, out of date, or incomplete (or becomes untrue, inaccurate, out of date, or incomplete), or We have reasonable grounds to suspect that the information provided by You is untrue, inaccurate, out of date or incomplete, We may, at Our sole discretion, suspend Your Account with Us.

7. PROTECTION OF YOUR INFORMATION

7.1 The security of Your Information is important to Us. We have adopted reasonable security practices and procedures to ensure that Your Information collected is secure. You agree that such measures are secure and adequate. We restrict access to Your Personal Information to Us and Our employees, agents, and third-party service providers who need to know such Information for your access and use of Our Service and provided that such entities agree to abide by this Privacy Policy.
7.2 While We will endeavor to take all reasonable and appropriate steps to keep secure any information which We hold about You and prevent unauthorized access, You acknowledge that the internet is not 100% secure and that We cannot provide any absolute assurance regarding the security of Your Information. We will not be liable in any way in relation to any breach of security or unintended loss or disclosure of information caused by Us in relation to Your Information.
7.3 Due to the communications standards on the Internet, when a User visits the Application and/or Services, We automatically receive the URL of the site from which anyone visits. We also receive the Internet Protocol (IP) address of each User’s device/server, User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of the User’s ISP. This information is used to analyze overall trends to help Us improve its Service. The linkage between the User’s IP address and the User’s Personal Information is not shared with or disclosed to third parties.
7.4 Notwithstanding the above, We may share and/or disclose some of the aggregate findings in anonymized form (that cannot be identified personally) with advertisers, sponsors, investors, strategic partners, and others in order to help grow Our business.

8. YOUR FINANCIAL INFORMATION

We may require the User to pay with a credit card, wire transfer, debit card, or cheque for Services for which subscription amount(s) is/are payable. We will collect such User’s credit card number and/or other financial institution information such as bank account numbers and will use that information for the billing and payment processes, including but not limited to the use and disclosure of such credit card number and information to third parties as necessary to complete such billing operation. Verification of credit information, however, is accomplished solely by the User through the authentication process. Users’ credit card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the highest possible degree of care as per current technology. However, We provide you an option not to save your payment details. User is advised, however, that internet technology is not completely safe and User should exercise discretion on using the same.

9. SHARING AND TRANSFER OF YOUR INFORMATION

9.1 We may exchange, transfer, share, part with all or any of Your Information, across borders and from India to any other country across the world with Our agents / third-party service providers, banks, and financial institutions for the purposes specified under this Privacy Policy or as may be required by applicable law or in case of sale, acquisition, merger or bankruptcy involving Us.
9.2 You acknowledge that some countries where We may transfer Your Information may not have data protection laws which are as stringent as the laws of India.
9.3 You acknowledge that it is adequate that when We transfer Your Information to any other entity within or outside India, We will place contractual obligations on the transferee which will oblige the transferee to adhere to the provisions of this Privacy Policy.

10. RETENTION OF YOUR INFORMATION

10.1 We will retain your information for as long as your account with the Services is active and as needed to provide You the Services.
10.2 We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force.
10.3 After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes.
10.4 Please note that your withdrawal of consent or cancellation of account may result in Us being unable to provide you with Our Services or to terminate any existing relationship We may have with you.

11. CHILDREN'S AND MINOR'S PRIVACY PRIVACY

We strongly encourage parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other Personal Information online without parental permission. Although Our Services are not intended for use by minors, if You are a minor, You may use Our Application and Services only with the involvement of a parent or guardian and through a Parent controlled Account.

12. OPT OUT

If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please send us an email at the email provided below. We reserve the right to continue to keep a copy of any of your Personal Information if required by law. We may use any aggregated/anonymized data derived from your Account, in a matter which shall not infringe upon your privacy.

13. NO SPAM

We maintain a strict “No-Spam” policy, which means that We do not intend to sell, rent, or otherwise give your e-mail address to a third party without your consent.

14. COOKIES

We use Cookies and similar tracking technologies (For example, Web beacons, Pixels, Software Development Kits (SDKs), etc) to track the activity on Our Service and store certain information. Some of these cookies are essential for Us to provide You with Our Service. We or our third-party service providers may use cookies, mobile app analytics, and similar technologies to track visitor activity and collect data while You use/access Our Service. We may combine this data with other Personal information We have collected from the User. “Cookies” means small pieces of information used to store on web browsers that the Website can retrieve at a later time. Cookies are used to receive and store identifiers and other information on computers, phones, and other devices. Cookies include other technologies, including data that we store on Your web browser or device, identifiers associated with Your device, and other software, which are used for similar purposes. Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your device when You go offline, while Session Cookies are deleted as soon as You close your web browser. You can change cookie settings in the help section of Your browser. You should be aware that the deactivation of cookies can influence Your experience of Our Service.

15. LINKS

Our Service may contain links to other websites that are not operated by Us. If You click on a Third-party link, You will be directed to that third party’s website and/or mobile application or similar service. We strongly advise You to review the Terms and/or Privacy Policy and/or supplementary rules/guidelines of every website/mobile application You visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services. You further acknowledge and agree that We shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such content, goods, or service available on or through any such websites or services.

16. COMPLIANCE WITH DATA PROTECTION LAWS

The Service accessed and used may be regulated by the applicable local laws and regulations on the protection of natural persons with regard to the collection, use, storage and processing of personal data and on the free movement of such data. You may reach out to Us at the email provided in Grievance Redressal Mechanism with the subject line “Data Protection compliance”. We respond to all requests We receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws of India.

17. CHANGES TO PRIVACY POLICY

We may update Our Privacy Policy from time to time. We will notify You of any updation by posting the new Privacy Policy on this page and update the “Last updated Notice” date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

18. GRIEVANCE REDRESSAL MECHANISM

To report any grievance with respect to the Application or Our Services, including any discrepancies and grievances with respect to the processing of information, you can contact our Grievance Officer at: Name: CA Akhil Kumar Address: C 5, 2nd Floor K K Apartment Opposite Narmada Bhawan (Near Ganna Sansthan) Dalibagh – Lucknow Pin -226001 Phone: 91-94150-20199 Email: akhil@drcfo.in

19. CONTACT INFORMATION

If you have any questions concerning the Company, the Application, the Terms, this Agreement, the Services, or anything related to any of the foregoing, or you wish to give your comments/feedback, You can reach us at the following email address mentioned below or using the Contact Us option in the Application. Unless otherwise specified herein, all notices or other communications under or in connection with this Agreement shall be given in writing and may be sent by personal delivery or post acknowledgment due) or courier (with POD) or E- mail as mentioned below. Any such notice or other communication will be deemed to be effective if sent by personal delivery, (when delivered) if sent by registered post (ack due) (on actual receipt), and if sent by courier (on actual receipt), and if sent by E-mail, (on receipt of confirmation to the correct Email id). Name: CA Akhil Kumar Designation: CEO Address: C 5, 2nd Floor K K Apartment Opposite Narmada Bhawan (Near Ganna Sansthan) Dalibagh – Lucknow Pin -226001 Email ID: akhil@drcfo.in

DRCFO MANAGEMENT CONSULTANTS PRIVATE LIMITED (hereinafter the “Company”, “We”, “Us”, and “Our” interchangeably) is the owner of the Website www.drcfo.in and the Mobile Application (hereinafter “Application” which includes the Website, Software program, data and documentation related thereto), and provides services related to health data management and online appointments with healthcare professional and other related services (collectively referred to as “Service/Services”) for integrated health care management for patients. This Privacy Policy must be read in conjunction with the Terms of Use. Any capitalized term used but not defined in this Privacy Policy shall have the meaning attributed to it in our Terms of Use. We are committed to Your privacy. This privacy policy (“Privacy Policy”) applies to Your use of and access to the Services and the collection, use, storage, sharing, processing, disclosure, and transfer of Your Information including Your Personal Information when You access and/or use the Services. You are advised to carefully read this Privacy Policy before using or accessing any of Our Services. Our Privacy Policy is applicable to every User who accesses our Application and/or uses Our Services (referred to as “You”, “User” or “Your” as applicable) from any device.

20. CONSENT

20.1 By using the Services or by otherwise voluntarily providing us Your information, You will be deemed to have read, understood, and agreed to the practices and policies outlined in this Privacy Policy and agree to be bound by the same.
20.2 You acknowledge that You are providing Your Personal Information out of Your free will.
20.3 You hereby consent to Our collection, use and sharing, storage, processing, and disclosure of Your information as described in this Privacy Policy.
20.4 If You use the services on behalf of someone else, You represent that You are authorized on behalf of such User by such User to accept this Privacy Policy, and consent to Our collection, use, and disclosure of such information as described in this Privacy Policy.
20.5 We reserve the right to amend the portions of terms of this Privacy Policy by way of modification, addition, or deletion, at Our sole discretion, at any time. The last updated date on the top of the page indicates when the Privacy Policy was last updated. If you do not agree to the amendments in this Privacy Policy at any time, do not use any of the Services any further.
20.6 You have the option not to provide Us the Personal Information. You also have the option to withdraw Your consent at any point. If You do not provide us with Your Personal Information or if You withdraw the consent at any point in time, You shall not be able to access and use Our Services.

21. SCOPE

22. COLLECTION OF PERSONAL INFORMATION

22.1 We may ask You to voluntarily provide Us with certain information that personally identifies You or could be used to personally identify You. You hereby consent to the collection of such Information by Us.
22.2 Without prejudice to the generality of the above, Personal Information collected by Us for Your registration to Our Services may include (but is not limited to) the following:

22.2.1Name
22.2.2Date of Birth
22.2.3Email address
22.2.4Phone Number
22.2.5Gender
22.2.6Location
22.2.7Pin code

22.3 Without prejudice, to make full use of Our Services and best meet Your needs, Information collected by Us may include (but is not limited to) the following:

22.3.1 data regarding your usage of the services and history of the appointments made by or with You through the use of Services
22.3.2 sensitive financial information such as bank accounts, credit, and debit card details, or other payment instrument details;
22.3.3 biometric information
22.3.4 medical records and history
22.3.5 physical, physiological, and mental health conditions
22.3.6 other information that You voluntarily choose to provide to Us

22.4 We shall be free to use, collect and disclose information that is freely available in the public domain without your consent.
22.5 We may also seek permission to use the camera, microphone, and phonebook/contact data at points where required.
22.6 We may also collect information other than Personal Information from You when You visit and /or use the Application. Such information may be stored in server logs. Such Non-Personal Information would not assist us to identify You personally. Such Non-Personal Information may include

22.6.1 Your usage details such as time, frequency, duration and pattern of use, features used and the amount of storage used,
22.6.2 Master and transaction data and other data stored in Your user account,
22.6.3 Internet Protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system, and other visitor details collected in Our log files.

23. METHODS TO COLLECT INFORMATION

23.1 The methods by which We collect Your Information include (but are not limited to) the following:

23.1.1 when You register on Our Application;
23.1.2 when You create a profile on Our Application or as part of Services;
23.1.3 when You provide Your Information to us;
23.1.4 when You use the features on Our Application and/or when You use Services;
23.1.5 when You access Applications or Services;
23.1.6 by use of cookies

24. ACCURACY AND UPDATION OF YOUR INFORMATION

24.1 We collect Your Information for various purposes, an indicative non- limiting list of such purposes is mentioned below:

24.1.1 in order to enable You to use the Application and utilize the Services. For instance, you may provide Your health-related information on the Website in order to consult privately with a Practitioner, or You may provide Your financial information in order to process a payment which You need to make on the Application; xx. to respond to Your inquiries;
24.1.2 to provide You with information about products and services available on the Application;
24.1.3 to personalize Your experience on the Application;
24.1.4 to help You address Your problems incurred on the Application including addressing any technical problems;
24.1.5 for proper administering of the Application;
24.1.6 to conduct internal reviews and data analysis for the Application (e.g., to determine the number of visitors to specific pages within the Website);
24.1.7 to improve the services, content, and advertising on the Application;
24.1.8 to protect the integrity of the Application;
24.1.9 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;
24.1.10 to conduct analytical studies on various aspects including User behavior, User preferences, etc;
24.1.11 analyzing anonymized practice information for commercial use;
24.1.12 processing payment instructions including those through independent third-party service providers such as payment gateways, banking, and financial institutions, pre-paid instrument and wallet providers for the processing of payment transactions or deferral of payment facilities;
24.1.13 analyzing software usage patterns for improving the utility of Our Services;
24.1.14 for communication purposes so as to provide You with a better way of booking appointments and for obtaining feedback in relation to the Practitioners and their practice;
24.1.15 debugging customer support-related issues;
24.1.16 for the purpose of contacting You to complete any transaction if You do not complete a transaction after having provided Us with Your contact information in the course of completing such steps that are designed for the completion of the transaction;
24.1.17 to make disclosures as may be required under applicable law.

25. ACCURACY AND UPDATION OF YOUR INFORMATION

25.1 You are responsible for maintaining the accuracy of the information You submit to Us, such as Your contact information provided as part of account registration.
25.2 If your Personal Information changes, You may correct, delete inaccuracies, or amend information by making the change in Your profile and informing us at the email provided below or using the Contact Us option.
25.3 We will make good faith efforts to make requested changes in Our then active databases as soon as reasonably practicable.
25.4 If You provide any information that is untrue, inaccurate, out of date, or incomplete (or becomes untrue, inaccurate, out of date, or incomplete), or We have reasonable grounds to suspect that the information provided by You is untrue, inaccurate, out of date or incomplete, We may, at Our sole discretion, suspend Your Account with Us.

26. PROTECTION OF YOUR INFORMATION

26.1 The security of Your Information is important to Us. We have adopted reasonable security practices and procedures to ensure that Your Information collected is secure. You agree that such measures are secure and adequate. We restrict access to Your Personal Information to Us and Our employees, agents, and third-party service providers who need to know such Information for your access and use of Our Service and provided that such entities agree to abide by this Privacy Policy.
26.2 While We will endeavor to take all reasonable and appropriate steps to keep secure any information which We hold about You and prevent unauthorized access, You acknowledge that the internet is not 100% secure and that We cannot provide any absolute assurance regarding the security of Your Information. We will not be liable in any way in relation to any breach of security or unintended loss or disclosure of information caused by Us in relation to Your Information.
26.3 Due to the communications standards on the Internet, when a User visits the Application and/or Services, We automatically receive the URL of the site from which anyone visits. We also receive the Internet Protocol (IP) address of each User’s device/server, User’s computer operating system and type of web browser the User is using, email patterns, as well as the name of the User’s ISP. This information is used to analyze overall trends to help Us improve its Service. The linkage between the User’s IP address and the User’s Personal Information is not shared with or disclosed to third parties.
26.4 Notwithstanding the above, We may share and/or disclose some of the aggregate findings in anonymized form (that cannot be identified personally) with advertisers, sponsors, investors, strategic partners, and others in order to help grow Our business.

27. YOUR FINANCIAL INFORMATION

28. SHARING AND TRANSFER OF YOUR INFORMATION

28.1 We may exchange, transfer, share, part with all or any of Your Information, across borders and from India to any other country across the world with Our agents / third-party service providers, banks, and financial institutions for the purposes specified under this Privacy Policy or as may be required by applicable law or in case of sale, acquisition, merger or bankruptcy involving Us.
28.2 You acknowledge that some countries where We may transfer Your Information may not have data protection laws which are as stringent as the laws of India.
28.3 You acknowledge that it is adequate that when We transfer Your Information to any other entity within or outside India, We will place contractual obligations on the transferee which will oblige the transferee to adhere to the provisions of this Privacy Policy.

29. RETENTION OF YOUR INFORMATION

29.1 We will retain your information for as long as your account with the Services is active and as needed to provide You the Services.
29.2 We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force.
29.3 After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes.
29.4 Please note that your withdrawal of consent or cancellation of account may result in Us being unable to provide you with Our Services or to terminate any existing relationship We may have with you.

30. CHILDREN'S AND MINOR'S PRIVACY

31. OPT OUT

32. NO SPAM