Last Updated: September 7, 2023
This Privacy Policy (“Policy”) describes the types of information collected through the www.devops.burnbootcamp.com website, online store front operated by our affiliate Burn Retail, LLC (the “Store”) (collectively, the “Site”), associated mobile application (the “App”), and visitors to our Burn Boot Camp Gym locations (“Gyms,” whether owned by us or a franchisee), (collectively, the “Services”) and our practices for how the information collected is used, shared, and protected.
Kline Franchising, Inc., d/b/a Burn Boot Camp™ (together with its affiliates, “Burn Boot Camp”, “we”, “us,”or “our”) and its suppliers and franchisees may collect or receive specific information that identifies you in connection with your access to and use of the Site (together, “Personal Information”). This Policy is incorporated into and made a part of our Terms of Use (“Terms”) located here.
By accessing our Site, using our Services, or by otherwise entering into our Terms, you acknowledge on behalf of yourself and any organization or company that you represent (together, “you” or “your”) that you have read and understand this Policy. If you object to this Policy, do not access, or use the Site or Services.
Your privacy is very important to us. If you choose to provide Personal Information to us that may personally identify you such as your name, email address, or phone number we will collect, use, disclose, and protect the information pursuant to this Policy. If you have any questions or concerns about our use of your Personal Information or other information collected through the Site or your use of our Services, please contact us using the contact information provided at the end of this Policy.
1. Personal Information We Collect
We collect Personal Information directly from you, from third parties when you use certain of our Services and through various automated means. The types of Personal Information we collect may include:
- Contact Information, such as your name, address, zip code, mobile phone number and email address.
- Demographic information, such as your date of birth.
- Physical information such as your hieght, weight, and calorie expenditure.
- Account information, if you set up an account through our Site or App, such as your username and password and account transactions.
- Financial information when you make a purchase through our Store or App, register for a membership, or sign up for classes whether live in-person with a franchisee or on-demand with us via the App.
- Transaction and anticipated transaction information when you sign up for a membership or make purchases through the Site or App, such as your order history, purchase frequency, products you browse or place in your shopping cart, and your signature at point of sale.
- Electronic information such as your internet browsing history, search data, browser type, IP address, device identifier, mobile advertising identifier, internet service provider, and analytics related to your interactions on the Site or App.
- Interactions that you have with us, such as emails, call recordings, security video from store visits, surveys that you respond to, and promotions with which you participate.
- General geolocation information, such as gym locations when you sign up for classes, your IP address and approximate location data obtained through wifi, WLAN or bluetooth access points.
2. Sources of Personal Information
The Personal Information that we may collect from or about you broadly falls into the following categories:
Personal Information we collect directly from you. We will collect any Personal Information from or about you that you choose to provide to us.
- Account sign up or trial registration: This may include your name, user name, age, location, physical address, email address, payment information, and telephone number when you register for an account through the Site or the App. Personal Information must be provided, for example, when creating your Burn Boot Camp account; to purchase products using the Site or App; when you submit a job application or career inquiry; when you provide User-Generated Content (as discussed below); to sign up for Burn Boot Camp’s newsletter; when you fill out forms or questionnaires on the Site or App; and when responding to communications from us (e.g., surveys, promotional offers, registration confirmations). If you choose to download the App or create an account on the App, we will also collect information relating to the device(s) you register. The information collected from users during the registration process is used to manage user accounts and may be disclosed to our franchisees and other third parties as needed, and further discussed below. You can visit the Site or App without providing your Personal Information to us, but you will be required to provide your Personal Information to request information from us, to register for an online Burn Boot Camp account, to purchase products using the Store or App, and to use certain other features of the Site or App.
- Fitness Data (“Fitness Data”): This consists of any information relating to your fitness performance and/or workouts, such as date and time of your workout, length of workout, number of calories burned, miles run, and heart rate information. If you download our App and have a Burn Boot Camp account, you will be prompted to track Fitness Data directly on your device(s). We will use this information to analyze your past and current fitness performance metrics, and to provide you with analytics about your fitness progress over time. Additionally, we will recommend workouts to you based on your preferences, practices, and previous exercises. We do not use or process your Fitness Data for identification purposes, and we will not disclose or otherwise disseminate Fitness Data unless it is directly authorized by you, or unless we aggregate the data.
- Direct Marketing Information: If you sign up or otherwise opt in to receive newsletters, promotions, or push notifications from us, you will need to provide your email address or consent to access to your device. We will use this information to provide you with promotional and other electronic communications. You may opt out of receiving promotional emails from us at any time by following the unsubscribe instructions contained in the applicable email. You may at any time opt-out from receiving push notifications through our App by changing the settings on your device(s). We may use third-parties to deliver these communications to you.
- Shopping & Payment Information: When you make purchases through our Store or App or sign up for a membership or classes through the Site or the App, we may collect your financial information including credit or debit card number, security code, billing address, your name, phone number, email, and shipping address. All financial information is provided directly to our PCI-compliant third-party payment processor. We do not directly access, handle, or store your credit or debit card information. Our payment processors may use your payment-related information in accordance with their privacy policies. We will maintain a record of the purchases that you make using our Store or App.
- User-Generated Content: You are responsible for any comments, data, text, images, video, audio, and other content, and material that you create, post, transmit, upload, publish, distribute, broadcast, submit, or otherwise provide via the Site or App, including by commenting on blog posts (together, “User-Generated Content”). User-Generated Content that you provide is posted at your own risk. We cannot guarantee that User-Generated Content you provide will not be viewed by unauthorized persons. You understand that, even after removal, copies of User-Generated Content you have provided may remain viewable in cached and archived pages and may have been copied or stored by Internet archives and other users. Burn Boot Camp will make User-Generated Content available to other users (as applicable and at its sole discretion) and will use and disclose User-Generated Content for the purpose for which it was provided as indicated at the point of collection. Please remember that any information you disclose in blog comments or other public areas of the Site will be accessible to others. You should exercise caution when deciding to disclose Personal Information in these public areas. For more information on User-Generated Content, please review our Terms[DC1] [DC2] .
- Career Opportunities: If you submit a job application or career inquiry , we will collect your resume and all other information and materials that you provide in the course of making that submission through our third -party vendor. We may use submitted information and materials to evaluate your qualifications and to otherwise consider or respond to your inquiry. Your submission of an application or inquiry does not in any way require Burn Boot Camp to review your information or consider you for employment. For more information on how information provided in the course of applying or being considered for employment by us is processed please refer to our Vendor’s Privacy Policy located here. [DC3] [DC4]
- Franchise Inquiries: If you fill out an inquiry form with respect to Burn Boot Camp franchising opportunities, you will need to provide various Personal Information pertaining to the prospective franchisee, including your name, location, and contact information and limited financial information pertaining to your business.
- Voluntary Customer Surveys: We may periodically conduct both business and individual customer surveys. We encourage our customers to participate in these surveys because they provide us with important information that helps us to improve the types of products and services we offer and how we provide them to you.
We may take the information we receive from individuals responding to our surveys and combine and aggregate it with the responses of others, to create broader, generic responses to the survey questions. We will also use that aggregated information to improve the quality of our products and services and to develop new products and services. This aggregated (non-Personal Information) may be shared with third parties.
Information from Third Parties. We may receive Personal Information from various third-party companies, such as social media platforms, applicant management vendors, and data brokers. We may combine our data with Personal Information and other information provided by such third-party companies. By combining our data with data collected from third party companies we can improve our ability to market our products and Services to you.
We are active on social media, including Facebook, TikTok, YouTube, X (formerly known as Twitter), Instagram, and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and App and our Social Media pages any comments or content that you post on our Social Media pages.
The Site allows you to connect and share data with Social Media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media platforms to facilitate those communications and features. The Site may use advertising networks and services offered by Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access the Site.
Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
Information from Automated Data Collection Technologies. In some instances, Personal Information may be automatically collected when you visit our Site, use our App, visit a Gym, or make use of our Services.
- Physical locations: When you visit a Gym location, they may use security and other electronic tools that may record your presence and activity.
- Wifi or Bluetooth devices: When you visit a Gym location and have your wifi or Bluetooth enabled on your mobile device, we may collect information about your device and its use of the electronic networks at that location.
- Maps: The Site and App contain maps provided by third parties and/or service providers for your convenience. These maps may be provided using APIs and tracking technologies made available by the third party map provider. Burn Boot Camp and the map provider may collect data about how you interact with the maps. For example, Google may collect usage data on maps embedded on the Site. Even if you do not interact with the maps, Google may still collect certain information about your interactions with our Site and App if you are signed into your Google account when accessing our Site or App. Please see Google’s Privacy Policy for more information.
- IP Addresses and Related Data: The servers used to operate and provide the Site and App may collect data pertaining to you and the equipment, software, and communication methods you use to access the Internet and the Site, including Internet protocol (“IP”) addresses assigned to the computers and other devices from where you access the Internet, your Internet service provider (ISP), your device ID number, your approximate geographic location, technical information such as usage data, your web browser type, the pages you access on the Site and App, the websites you access before and after visiting the Site, the length of time you spend on the Site or App, date and time stamps, and clickstream data. Burn Boot Camp may use this information to administer the Site and App and their servers, to generate statistical information, to monitor and analyze traffic and usage patterns, to monitor and help prevent fraud, to investigate complaints and violations of our policies, and to improve content and the products, services, materials, and other content that we describe or make available (see also how we use Google Analytics/analytics services as described below). We may combine this information with other Personal Information and information obtained from third parties for security reasons and to protect our rights or the rights of others as discussed below. The suppliers that we use to provide the Site and App may collect information about your visits to the Site and App and other websites. Some of this information may be collected using cookies and similar tracking technologies as explained further below under “Cookies and Other Tracking Technologies.”
- Cookies and Other Tracking Technologies: The Site and App automatically uses cookies or similar tracking technologies to track your use of the Site or App in order to facilitate and enhance the user experience on the Site or App and for other purposes as described below. A “cookie” is a small piece of information that is stored on your device’s hard drive by your web browser when you visit certain websites and similar tracking technologies may be used in the App. We use cookies to track how you access and use the Site or App, to learn when and how users visit the Site or App, to learn how popular Site or App pages are and aren’t, to learn which search terms are used to find the Site, to learn which websites direct you to the Site, and to recognize Site or App users (whether or not the user has an online Burn Boot Camp account). We also use cookies and similar technologies to help display certain information on the Site and App and to improve your enjoyment of the Site or App, for example, by remembering your contact and other information when you access or use the Site or App, as well as for statistical purposes to improve the products and services we provide and to manage our telecommunications networks.
The Site may use both cookies that we implement, and cookies implemented by our suppliers and other third parties, such as advertisers. We do not control third-party cookies, or the information collected through them and expressly disclaim responsibility for information collected through them.
Most browsers automatically accept cookies. You can disable cookies but disabling cookies may impact your use and enjoyment of the Site. Most browsers allow users to manage cookies in the browser’s settings. For example, a browser may allow you to reject cookies from certain websites, reject certain types of cookies regardless of the website, reject or disable all cookies from all websites, and/or delete cookies stored previously. Some browsers also give you the option of being notified every time a cookie is sent to your browser by a website.
The types of information collected by a cookie and the purposes for which that information is used depends on the type of cookie. For more information on cookies, please visit https://allaboutcookies.org/what-is-a-cookie.
The Site and App may also use the following types of tracking technologies: web beacons (also called clear GIFs), flash cookies, and pixels (also called pixel tags). A web beacon is a tiny graphic with a unique identifier that functions similar to how cookies function. However, in contrast to cookies, web beacons are embedded invisibly on websites. Flash cookies collect and store information about your use of a website and are commonly used for advertisements and videos. Pixels can be placed on websites or within emails to track your interactions with those websites and when emails are opened.
How We Respond to Do-Not-Track Signals: Due to the automatic collection of data using cookies as described above, we currently do not honor “do not track” requests.
Location Information: In addition to the approximate geographic location information collected as discussed above, we may, with your consent, access more specific location information to enhance the user experience and increase the usefulness of the Site and App. This includes geographical location information collected by device-based location services (including GPS data). You may choose to allow us to access your location by granting the Site or App access to your location when prompted or through your device’s location services settings. Company also uses the Google Maps API(s). Pursuant to the Google Maps APIs Terms of Service, use of this location feature is also subject to Google’s Privacy Policy. For information on how Google categorizes location information, please visit Types of location data used by Google. Both the Google Terms of Service and Google’s Privacy Policy are incorporated into this Policy by this reference.
Analytics: The Site and App uses third-party analytics tools (e.g., Google Analytics) to collect and process data about your use of the Site or App, including when you visit the Site or App, URLs of the websites that you visit prior to visiting the Site and when you visit those websites, and IP addresses assigned to the devices from where you access the Internet. For more information on how Google uses this data, visit Google’s Privacy Policy and Google’s page on How Google uses data when you use our partners’ sites or apps. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each browser you use. Using the Google Analytics Opt-out Browser Add-on will not prevent Burn Boot Camp from using other analytics tools and will not prevent data from being sent to the Site itself or to Google. For more information about how Google Analytics uses cookies to measure user interactions on websites, visit Google Analytics Cookie Usage on Websites. You may disable cookies as discussed above, but that may impact your use and enjoyment of the Site.
Advertising Networks, Personalized Advertising, Remarketing, and Retargeting: The Site and App may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including advertising services provided by Facebook (sometimes referred to the Facebook “tracking pixel”). These services collect information about your visits to and interactions with the Site and App and other websites and aps and will use that information to target advertisements for goods and services. The information collected may be associated with your Personal Information. These targeted advertisements may appear on the Site or on other websites. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of web browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the Site and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.
If you have a Facebook account but do not wish Facebook to collect data relating to you via the Site or App, we suggest that you: (a) hide social media platform plug-ins using an ad blocker; (b) always log off completely from Facebook before visiting other websites and delete all related cookies; and (c) where the option is available, disable the advertising services and networks operated by Facebook.
Additionally, we may have enabled and implemented the following Google Analytics Advertising Features: Remarketing with Analytics, Demographics and Interest reporting, Campaign Manager integration, Display & Video 360 integration, Google Display Network (GDN) Impression Reporting, and Segments. Remarketing with Analytics uses Google Analytics cookies to serve advertisements to you across the Internet based on your visits to the Site. Demographics and Interest reporting uses a third-party cookie to collect information about our Site traffic by tracking users across websites and across time, which generates a report for us to better understand Site users. Campaign Manager integration allow us to view, analyze, and create remarketing lists using our Campaign Manager data in Google Analytics. Display & Video 360 integration allows us to create remarketing lists in Google Analytics and have those lists available in Display & Video 360. Google Display Network (“GDN”) Impression Reporting allows us to measure the impact of unclicked GDN Display ad impressions on website behavior and conversions. Segments allows us to isolate and analyze subsets of Site users by sorting our Google Analytics data. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.
To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Please remember that changing your settings with individual web browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time.
Embedded Content: The Site and App may incorporate content, including feeds, scripts embedded in the Site’s code, and visible content (e.g., videos), provided by third parties. In some cases, those third parties collect data about how you interact with their content. For example, YouTube may collect or otherwise have access to usage data on YouTube videos embedded on the Site or App as described in YouTube’s Privacy Policy.
3. How We Use Personal Information
In addition to the uses described above, Burn Boot Camp and its suppliers may use Personal Information as described below. We do not use, sell, rent, or otherwise disclose Personal Information except as stated in this Privacy Policy and as required or permitted by applicable law.
For the Purpose Collected & Communicated with You: We will use your Personal for the purpose for which it was collected, for example, to process and communicate with you in connection with your requests and purchases, to administer your Burn Boot Camp account, to consider and respond to job applications you have submitted, to administer Burn Boot Camp business activities, to provide customer support to Site and App users, to communicate with you in connection with your account, and to provide you with information and communications that you request. Your location information will be used to find a Burn Boot Camp location near you. We will make certain Personal Information, including User-Generated Content, available to other users of the Site as mentioned above. For example, if you comment on a Burn Boot Camp blog post, other Site visitors will be able to view and share that information.
We may use Personal Information to notify you of changes made to the Services (e.g., changes to our Terms of Use or this Policy) and to provide you with promotional materials and other communications as described above. If you send us an email inquiry, we will use your email address to respond to the email inquiry we receive. If you contact us for support or assistance in using the Site or App, we may use Personal Information to determine whether your system meets the minimum requirements needed to access and use the Site or App and otherwise to contact you regarding your request.
To Provide You Our Services: We may use your Personal Information to provide you Services through our App, the Site, or Gym locations. This includes tailoring specific classes or content to you, showing you Gyms near you based on your location information, scheduling and signing up for workout sessions at Gyms, scheduling or signing up childcare services at Gyms, or to track your visits at our Gyms.
To assist Suppliers in Providing You Our Services: We may use Personal Information to enable our suppliers, who we use to support our business, to provide you with our Services. These suppliers include our Site and App management and hosting suppliers, cloud storage providers, IT security providers, payment processors, online storefront providers, order fulfillers, customer support providers, portal providers, marketing and public relations service providers, and email service suppliers.
To assist Franchisees in Providing You Our Services: Each individual Burn Boot Camp location may be owned by a franchisee as a separate legal entity from us. As a result, Personal Information may be disclosed to and used by those individual franchisee entities and locations at which you have inquired about Services, signed up for Services, or done business so that those locations can respond to your requests and provide products and Services to you and for analytical and reporting purposes. Personal Information that you share with any individual location may be used as part of your Burn Boot Camp account. Franchisee Gym locations may use your Personal Information for weekly protocols, management and reporting obligations, or focus meetings to help improve your experience and the level of Services provided by such franchisee gym location.
Evaluation and Improvement of Our Services, User Demographics, and Aggregation: We may use Personal Information to customize Site and App content, promotional emails, and users’ browsing experience; to analyze, develop, and improve Site and App content and materials and products and services we make available (including the Site); to inform marketing and communication plans and strategies; to understand user demographics and preferences; and to evaluate Site and App user needs. We may also aggregate Personal Information and other information to create aggregated data on Site and App users that describes users as a group but does not reveal the identity of individual users. We may use aggregated data to understand Site and App users’ needs and Site and App usage patterns, to determine what kinds of products and services we can provide, and to improve and enrich our products, our services, and the Site and App.
For Security and Protection of Rights: We may use Personal Information as required or permitted to respond to subpoenas, court orders, valid law enforcement requests, and other legal process, as well as to prevent fraud, establish or exercise our legal rights or defend against legal claims if we believe doing so is necessary, including sharing information necessary in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Burn Boot Camp’s Terms, identify, contact, or bring legal action in the event of a violation of our contracts, terms, or policies, or as may be otherwise required or permitted by law.
With Your Consent: With your consent, we may use your Personal Information in ways not specifically described in this Policy.
4. How We Disclose Personal Information
We may disclose your Personal Information to our personnel, our franchisees, and to the third parties for the purposes stated above and as further set for below:
- Affiliates: This includes our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Notice. Personal Information may be shared with individual franchisee entities and Gym locations at which you have inquired about Services, signed up for Services, or done business so that those locations can respond to your requests and provide products and services to you, and for analytical and reporting purposes. In addition, Personal Information that you share with any individual Gym location may be provided back to us and maintained by us as part of your Burn Boot Camp account.
- Service providers: We may disclose Personal Information with suppliers who we use to support our business. Our suppliers are bound by applicable law and contractual obligations to keep Personal Information confidential and are authorized to and may only use and disclose Personal Information as necessary for them to provide the applicable services to us and, as applicable, as provided by their own privacy policies as noted above.
- Business and marketing partners: This includes third parties with whom we collaborate on joint activities, with whom we have entered into joint marketing relationships or other joint ventures.
- Professional advisors: This may be lawyers, auditors, bankers and insurers, where reasonable in the course of the professional services that they render to us.
- Authorities and others: Law enforcement, government authorities, and private parties, pursuant to subpoena or other legal process, and otherwise as we believe in good faith to be necessary or appropriate for legal compliance or to protect the rights, property, or safety of us or others, including credit risk and fraud reduction.
- Business transfers: Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in us or our affiliates (including, in connection with a bankruptcy or similar proceedings).
We may disclose aggregated information about our customers, Site and App users, Site and App traffic patterns, and information that does not identify any individual without restriction.
5. Data Retention & Security
Burn Boot Camp retains Personal Information for as long as you use our Services and as necessary to fulfill the purpose(s) for which it was collected in accordance with our legal or regulatory obligations.
Burn Boot Camp has implemented technical and organizational security measures to help protect against the loss, misuse, and alteration of information under our control, including encrypting information passed between our systems and your browser. The storage and communication of information online can never be completely secure, however you should take steps to protect against unauthorized access to your account, personal computer, or mobile phone to minimize such risks. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized access. If you become aware of any breach of security or this Policy, please notify us via email at info@devops.burnbootcamp.com immediately. If our security system is breached, we will notify you of the breach only if and to the extent required under applicable law.
6. Third-Party Websites and Services
The Site may link to, or be linked to, websites and services not maintained or controlled by Burn Boot Camp. Burn Boot Camp is not responsible for the privacy policies or practices of any third parties or any third-party websites or services. This Policy does not apply to any third-party websites or to any personal or other information that you may provide to third parties. You should read the privacy policy for each website that you visit.
7. Access from Outside the United States
We control and operate our Services from the United States and store all information we collect domestically. If you are using the Site or App from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States (where our and our suppliers’ servers and databases are located and operated). The data protection laws and regulations of the United States might not be as comprehensive as those in the country from which you access the Site or App. By using our Site or App, you are expressly consenting to the transfer to and from, processing, usage, sharing, and storage of your information in the United States.
8. Children’s Privacy
Our Site is not directed at or intended for use by children under 13 years of age. If you become aware that an individual under 13 years old has provided us with Personal Information, please contact us at info@devops.burnbootcamp.com. Burn Boot Camp does not knowingly collect or use information from children under 13 through the Site. If you are under 13 years old, do not use or provide any information on our Site.
9. Contact Us
If you generally have any questions, complaints, or requests please contact us with your name and contact information via one of the following methods:
- Email: info@devops.burnbootcamp.com, or by
- Mail at:
Kline Franchising Inc.,
17036 Kenton Dr.
Cornelius, NC 28031
10. Updates to this Policy
We reserve the right to revise, amend, and modify this Policy at any time. All changes will be effective immediately upon posting to the Site and App unless otherwise noted. Material changes will be visibly posted on the Site and App or otherwise communicated to you. Your continued use of our Services after any changes are implemented constitutes your acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Policy, please do not use our Services.
[DC1]When posting the privacy policy, please cross link to terms here.
https://devops.burnbootcamp.com/terms-of-use/ [DC2]
[DC3]When posting the privacy policy, please link to ADP’s privacy Policy here.