Legal

Privacy Policy

Version adopted February 12, 2024

ProGuitar Sweden AB (hereinafter referred to as “Songally”, “we”, “us” and “our”) believes in an open and transparent process with regard to which personal data we process and for which purposes. It is also important to us that we protect your personal data.

This Privacy Policy describes how Songally processes your personal data, for example in connection with provision of our current or future services, including Songally and Songally (jointly “Services”) and otherwise when you are in contact or interact with us and/or visit our website(s). We also describe the rights that you have regarding our processing of your personal data. The data are processed in different contexts and for different purposes which are set out under the headings below. If you have any questions concerning the processing of your personal data, you are welcome to contact us using any of the contact details provided at the end of this document.

This Privacy Policy is addressed to those who:

are a user of any of our Services;
are creating a member account with us;
visit our website;
receive our marketing;
communicate with us;
is or represent one of our current or future suppliers or subcontractors, or
take part in a recruitment process with us.

1. Who is responsible for the processing of your personal data?

Songally is the data controller responsible for the processing of your personal data in accordance with this Privacy Policy. We are generally not jointly controlling your data together with other parties, but please note that we, in certain situations, will share your personal data with our partners (see more below). You can always contact ProGuitar with all questions about responsibility for the processing using the contact details provided at the end of this privacy policy.

To provide you with our Services, we cooperate with different partners and subcontractors. Such partners may be musical teachers, advertising networks, and marketing partners. We also link to third party service providers whose services are integrated with our Services through API, such as YouTube, Spotify and similar. Without the connection to third party services, you might not be able to get the full experience of our Services. Such third-party service providers may also process your personal data. For a full picture of how your personal data are processed, please review our third party notices (https://www.songally.com/legal/third-party-notice) and their privacy policies.

2. What personal data is processed and why?

Songally processes your personal data in different ways and for different purposes. Below, there is provided more detailed information about how we process your personal data in different situations, why we conduct the processing and the legal basis for our processing.

In the first instance and in almost every case, we obtain your personal data directly from you. We may also, in some situations, receive your personal data from our third-party services providers, distribution platform providers and other third parties whose services you are using when you are creating a member account or purchasing any of our Services. We are not buying or collecting any personal data from publicly available sources.

2.1 When purchasing our Services or creating a member account

Songally processes your personal data to be able to administer and complete your purchase of our Services (if applicable) irrespective if you have a member account with us. In general, we may process similar personal data when you purchase a Service (e.g., through a one-off payment) and when you are creating a member account with us. The type of personal data that we process may vary depending on the situation and what type of Service you are purchasing, as well as your location.

Why do we use your data? We use the data to administer, complete and follow up the purchase of our Services (e.g., to provide you with and retain information about the purchase) and to create your member account. We also use your personal data to adapt our content and Services in order to comply with applicable laws. Categories of personal data Identity and contact details (e.g., name, address, email, telephone number, age, etc.), in cases in which you provide such information to us. Order information and other communication between us. Information about you, including pseudonyms provided by third parties and login details. Payment information and payment history (if applicable). Credit card credentials (partial data, full data only available for payment service providers). IP address and cookies containing personal data. Location data and geo data.

Type of processing	Legal basis
Confirmation of your request and of your identity. Confirmation of your age. Creating your member account. Administration of your request, including enabling you to access your account and purchased Services.	Processing is necessary for us to be able to fulfil our agreement with you or to act upon request from you before a purchase is completed or a member account is created. Without the requested information, we cannot fulfil our obligations towards you.
Confirmation of your country of residence and/or your location. Adapting the range of our available Services depending on your location. Adapting our prices to your local currency and applicable taxes/fees of your jurisdiction.	Processing is necessary for us to fulfil our legal obligations to comply with applicable laws on copyrights, taxes and other laws that may affect the content of our Services available in your location.
Communication with you (confirmation per e-mail, planning, follow-up, evaluation, etc.)	Processing is necessary to fulfil our legitimate interest in the communication, planning, follow-up, and evaluation of questions regarding your request.
Administration of potential complaints, objections and warranty claims.	It is in our legitimate interest to process complete data about and in connection with a purchase to defend ourselves against and handle any warranty claims, objections, or complaints in relation to a purchase or your registration as a member with us.
Administration and handling of potential complaints and legal claims. Taking necessary actions to address your complaint or claim. Resolving any problem with your purchase or member account, to the extent action includes processing of your personal data.	It is in our legitimate interest to be able to defend ourselves against any potential complaints or assert any legal requirements and claims. To fulfil the agreement we have entered with you, including (i) fulfilling your purchase and (ii) creating your member account, it is our duty to resolve any problem as soon as possible. Sometimes such actions may include processing of your personal data.
Follow-up and reporting of our business transactions to enable business and product development.	It is in our legitimate interest to be able to develop our Services and our business. When reporting purchases internally, your personal data may appear in for example, contract documentation that is used as a basis for reporting.
Maintaining IT security and safeguarding your data and our services	It is in our legitimate interest to keep our Services and your data safe and secure. In some respects, preventing intrusions and ensuring safe Services may include processing your personal data for security purposes, e.g., to safeguard your member account and your safety when using our Services.
To comply with statutory and other regulatory requirements that apply to us, e.g., the Swedish Accounting Act.	If your personal data is contained in documents that must be saved for example, under rules in the Swedish Accounting Act, we process the data because it is necessary to fulfil our statutory and/or regulatory obligations or our obligations in accordance with a decision rendered by public authorities.

2.2 When using our Services

When you are using our services in logged-in mode, the Services are generating and processing different kinds of data. Such data may include your personal data, which we must process to provide you with our Services. Some processing is optional for you and such processing will only take place if you provide us with our consent, which means that you later have the opportunity to opt-out from such processing.

Please note that if you are using our free Services, without creating a member account or without logging in to your member account we only process limited personal data about you to provide the Services to you. Please see more about our processing in this regard below under “When using our websites”.

Why do we use your data? We use the data to be able to provide you our Services and to. We also use your personal data to suggest relevant parts of the service that we think may be of interest to you. In addition, we process data which may include your personal data or pseudonymized personal data to facilitate development of our current or future services and offers. Categories of personal data User data, including account details. Information about how you are using our Services. Location data and geodata. Technical details, including IP address and cookies. Information about your device that can be linked to you. User-generated data that contains personal data. Usage information. Data from third parties to connect to third party services. Other personal data which you provide us with.

Type of processing	Legal basis
Provision of our Services. Administration in connection therewith.	Processing is necessary for us to be able to fulfil our agreement with you. We cannot provide you with our Services without access to and processing of the relevant data.
Confirmation of your country of residence and/or your location. Adapting the range of our available Services depending on your location.	Processing is necessary for us to fulfil our legal obligations to comply with applicable laws on copyrights and other laws that may affect the content of our Services available in your location.
If applicable, to analyze your use of our Services and to provide you personalized suggestions within the Services (profiling).	Your consent. Please read more about our profiling below.
Use and analysis of data in aggregated format for the purpose of developing our future services and offers.	It is in our legitimate interest to evaluate, develop and improve our products. When we do this, it is of value for us to access the information that our Services generate. If we process your personal data for our service development purposes, we only do so in an aggregated and pseudonymized format.
Administration and handling of potential complaints and legal claims. Taking necessary actions to address your complaint or claim. Resolving any problem with your purchase or member account, to the extent action includes processing of your personal data.	It is in our legitimate interest to be able to defend ourselves against any potential complaints or assert any legal requirements and claims. To fulfil any relevant agreement we have entered with you, including (i) fulfilling your purchase and (ii) creating your member account, it is our duty to resolve any problem as soon as possible. Sometimes such actions may involve
Maintaining IT security and safeguarding your data and our services	It is in our legitimate interest to keeping our Services and your data safe and secure. In some respects, preventing intrusions and ensuring safe Services may include processing your personal data for security purposes, e.g., to safeguard your member account and your safety when using our Services.
To comply with statutory and other regulatory requirements that apply to us, e.g., the Swedish Accounting Act.	If your personal data is contained in documents that must be saved for example, under rules in the Swedish Accounting Act, we process the data because it is necessary to fulfil our statutory and/or regulatory obligations or our obligations in accordance with a decision rendered by public authorities.

2.3 When we send marketing to you

We process personal data in order to send marketing material to you. We also customize our marketing to provide you with relevant information that may be of your interest, which we base upon our conclusion about your use of our Services. Sometimes, this is performed by our partners (please see our third party notices for more information).

At any time, you have the right to object to such processing, which we base upon your consent. Irrespective of the basis on which we process your data to send marketing material, you always have the possibility of stopping such emails and other communications from us by contacting us (https://www.songally.com/contact) or using the communication channel specified in the mailing.

Why do we use your data? We use the data to provide you with marketing material in which we believe you have an interest or which you have requested us to send to you. Categories of personal data Identity and contact details (e.g. name, address, email, telephone number, etc.). Information about your purchase history and use of our Services. Your chosen preferences within our Services. Your activity when getting an e-mail from us, e.g. which links you click on.

Type of processing	Legal basis
Marketing of and information about our services and news. Sending e-mails and newsletters to you. Drawing conclusions of your interests and personalizing information based upon your use of our Services.	If you have an existing member account with us, we believe you are interested in receiving updates and information about our Services, in which we believe you may have an interest. Any personalizing of such information will however be based upon your explicit consent to such profiling activities. If we do not have a previous relationship, we will process your data based on the explicit consent that you have given us, e.g., when signing up for our newsletter.
If you withdraw your consent to us sending marketing to you or opt-out from our receiving marketing materials from us, we will register your contact details to make sure we do not send marketing to you in the future.	It is our legal obligation to follow applicable marketing laws, which stipulates we are not allowed to send marketing materials to you if you have withdrawn your consent or opted out from receiving such marketing.

2.4 When using our websites

We process personal data when you use our websites and for the reason where your usage requires some form of identification, for example in the form of cookies, IP addresses and similar. In the first instance, we process this type of personal data in order to give you a better user experience. We may also process your personal data to be able to show you the right content based upon your location.

Why do we use your data? We use the data to provide information about our Services and our offers, to give you a better user experience as a user and to be able to develop our Services and offers. Categories of personal data Identity and contact details (e.g. name, address, email, telephone number, etc.). Location data and geodata. Pixels that contain personal data. User-generated data that contains personal data. Technical details, including IP address and cookies. Information about your device that can be linked to you.

Type of processing	Legal basis
Processing necessary for you to use our website, such as the processing of your IP address and the placing of necessary cookies on your computer or phone.	Processing is necessary for our legitimate interest in being able to provide you with information and necessary features through our website and to provide you with the full user experience. In order to do so, we need to process certain data that may include your personal data.
Confirmation of your country of residence and/or your location. Adapting the range of our available Services depending on your location.	Processing is necessary for us to fulfil our legal obligations to comply with applicable laws on copyrights and other laws that may affect the content of our Services available in your location.
Use of data in aggregated format for the purpose of evaluating, developing, and improving our products and offers.	It is in our legitimate interest to provide you with information about our offer and evaluating, developing, and improving our website at the same time. When we do this, it is of value for us to access the date that is generated through your use of our website.
Administration of potential complaints, objections and warranty claims.	It is in our legitimate interest to process complete data in order to be able to defend ourselves against and handle any claims or complaints.

2.5 When you communicate with us

We will process personal data when you communicate with us via our website, social media, and email, irrespective of what your matter concerns.

Why do we use your data? We use your data in order to be able to respond to your requests, comments and posts on our social media and by email and then to continue to communicate with you in relation to such matters. Categories of personal data Identity and contact details (e.g. name, address, email, telephone number, etc.). Any username, other possibly provided user data, and profile picture if you contact us via social media. Technical details, including IP address and cookies. Any personal data including in the communication you send to us.

Type of processing	Legal basis
Confirmation of your identity and your contact details if necessary. Necessary processing for you to be able to communicate with us via social media and by email and in order for us to be able to reply to you.	The processing is necessary for our legitimate interest to assist you or the person or company that you represent and to respond to your requests, comments and posts, as well as your emails to us, to meet your expectations and to handle any legal claims.
Administration of potential complaints that are submitted to us via email or social media.	It is in our legitimate interest to process complete data in order to be able to defend ourselves against and handle any claims or complaints.
Administration and handling of legal claims.	It is in our legitimate interest to process complete data in order to be able to defend ourselves against and handle any legal claims.

2.6 When you are or represent one of our current or future suppliers or subcontractors.

We will process your personal data when you are or represent a supplier or subcontractor to us. The personal data processing may be done for the purpose of communicating with you, for the negotiation and signing of agreements, complaints, or error handling or for the management and administration of our professional relationship for other reasons.

Why do we use your data? We use your data to administer the contractual relationship, follow up on the products and services that you or the company that you represent purchase from or provide to us, to communicate with you and to handle any legal requirements. Categories of personal data Identity and contact details (e.g. name, address, email, telephone number, images, etc.). We may get this information directly from you or your employer or the company you represent. Order information or other communication in which you are listed as a reference person. Payment information and payment history.

Type of processing	Legal basis
Confirmation of your identity and your contact details. Administration of our order or the assignment (information, payment, delivery, etc.).	If you are a private individual or sole trader: The processing is necessary for us to be able to fulfil our agreement with you or act upon request from you before entering into an agreement, e.g., regarding your request for information, handling orders, invoice handling, performing payments, support, and administration of the contractual relationship. Without the requested information, we cannot execute the agreement. If you are a representative of the company that is our supplier or subcontractor: The processing is necessary in order to fulfil our legitimate interest in the preparation and administration of the agreement with the company that you are representing, as well as for the provision of information to you, the handling of orders, processing of invoices, performing payments and support and administration of the contractual relationship in your capacity as a representative for our supplier or subcontractor.
Requesting credit report	In some cases, it is in our legitimate interest to request a credit report before we execute the agreement to ensure that you or the person you are representing will have the financial capacity to execute the relevant agreement. If you are a private person or a sole trader, such credit report may include your personal data.
Communication concerning the agreement (planning, follow-up, evaluation, etc.)	Processing is necessary to fulfil our legitimate interest in the communication, planning, follow-up and evaluation of questions regarding the agreement with you or the company that you are representing.
Administration of potential complaints and objections.	It is also in our legitimate interest to be able to defend ourselves against and handle any claims or complaints in relation to a contractual relationship with you or the company you are representing.
Administration and handling of legal claims.	It is in our legitimate interest to process complete data in order to be able to defend ourselves against and handle any legal claims.
Necessary follow-up, administration and reporting concerning our agreements and business that enables business and product development.	It is in our legitimate interest to be able to develop our business and products. Your personal data may appear in documents used as a foundation for internal reporting.
In order to comply with statutory and other regulatory requirements that apply to us, e.g. the Swedish Accounting Act.	If your personal data is contained in documents that must be saved for example, under rules in the Swedish Accounting Act we process the data because it is necessary to fulfil our statutory and/or regulatory obligations or our obligations in accordance with decisions rendered by public authorities.

2.7 When you participate in a recruitment process with us

We process personal data when you are involved in a recruitment process with us, or when you otherwise participate in our business as a consultant or similar. In some cases, we cooperate with external recruitment companies in our recruitment processes. In such cases, we will provide you with particular information about it. If you are a consultant, it may be that your employer has provided us with your personal data. We may also process your personal data because you have been indicated as a reference by another person who has applied for a job with us.

Why do we use your data? We use your data in order to recruit staff and consultants and where applicable, to keep in touch with potential candidates so as to provide information about relevant vacancies in the future. Categories of personal data Identity and contact details (e.g. name, address, email, telephone number, images, etc.). Personal data that you disclose to us in your application, during interviews and tests and that can be found in the documents, certificates, grades and similar that are included as part of your application. Personal data that is available in publicly available registers and social media. Other personal data about you as a reference to the person applying for a job that has been provided to us in the context of a recruitment procedure.

Type of processing	Legal basis
Processing necessary for the administration, organization, and completion of general and specific recruitment processes.	Processing is necessary for us to be able to fulfil our agreement with you or take action upon request from you before an agreement is concluded. Without the requested information, you cannot apply for a job with us.
Other processing to administer, organize and complete general and specific recruitment processes.	It is in our legitimate interest to ensure that we interact with the individual who is applying for a position with us or who will be involved in our business as a consultant or similar, and that we can evaluate the application submitted by the individual. The same applies to the other data generated during interviews and tests or that is included in the application in one way or another.
Necessary processing in order to meet the requirements of applicable legislation in our recruitment process.	Some processing is necessary for us to be able to meet the statutory requirements in relation to recruitment and employment, etc. If we do not receive the requested information, we may have an obligation to reject your application or to reject your involvement in our business.
In some cases, retention may be for up to six (6) months for the purpose of informing and maintaining contact for potential services in the future.	If we are given your consent, we will retain your data and during that time possibly process your personal data for the purpose of contacting you and providing information about work opportunities or assignments that we think would be suitable for you. You can withdraw your consent at any time by contacting us.

3. Who has access to your personal data?

We will never sell personal data to third parties, e.g. for commercial purposes. However, in some cases we will transfer your personal data to third parties - see additional information about different categories of recipients under the headings below. The transfers are necessary in such cases to enable the operation of our business. When transferring your personal data, we have ensured that the responsibility for this is regulated by agreements and other appropriate safeguards.

If you would like to receive more detailed information about who will receive your information, you are always welcome to contact us. We also recommend you read our third party notices, where you can read more about our partners’ processing of your personal data.

3.1 Transfer to suppliers and subcontractors

We may receive or send some of your personal data to the suppliers and subcontractors to provide you with our Services. This may be the case when you have ordered a video lesson, for instance. We also share your data with our marketing partners.

3.2 Transfer to third party service providers

When you are using our Services, third parties may collect your personal data, as well. Sometimes, we also share your personal data with them to provide you with our Services and to enable you the full experience of our Services.

3.3 Transfer to third countries outside the EU/EEA

Songally processes your personal data within the EU/EEA and outside the EU/EEA, primarily in the US. In cases in which data is handled outside the EU/EEA (in what is referred to as a “third country”), there will be a decision by the European Commission that either the third country has adequate protection for your personal data (an adequate level of protection) with our without extra safeguards, or that there are other appropriate safeguards for your data that ensure that your rights are protected, such as the use of standard contractual clauses. If deemed necessary, will we take additional security measures to safeguard your privacy, e.g., limitations of the personal data subject to a transfer, encryption or pseudonymization of your personal data.

If you would like to receive a copy of the safeguards that we use or information about where they are available, you are welcome to contact us.

3.4 Authorities

If we have a legal obligation to do so, we will disclose your personal data to authorities upon request from the authority, from you or on our own initiative.

3.5 Security companies, debt collection companies, other legal assistants, courts

We may disclose your information to security companies, debt collection companies, legal representatives or courts if it is necessary to protect our rights, e.g. to investigate potential crime or to detect, prevent or disclose fraud or other security issues or for example, in order to demand payment.

3.6 IT suppliers and partners that perform assignments for us

We may disclose your information to our product and service providers, such as wireless service providers, systems providers, payment service providers, companies that manage and operate our website, send messages or carry out data analytics to the extent necessary for us to conduct our business or fulfil our obligations to you in accordance with the purposes referred to above.

3.7 Financial service providers

We may disclose your information to system suppliers, advisors, banks, our other financial partners, and other financial parties to process, store or manage payments and/or other financial information to enable us to conduct our business or fulfil our obligations to you.

3.8 Potential investors and venture capitalists

In case we or our owners invite third parties to invest in our business, we may share some of your personal data in aggregated and/or pseudonymized format with such investors and venture capitalists and their advisors, to let them perform a due diligence of our business, subject to customary confidentiality and no use obligations from such recipients. We will in such case provide you with more information as soon us we are allowed to, due legal obligations on confidentiality and/or inside information.

4. Use of automated individual decision-making and profiling

Automated decision-making may to some extent occur or be enabled in the software upon which our Services are based. This means that the Services that you use may make automatic decisions based on how you interact with our Services and how you use our Services, e.g. by showing you content that may be of your interest. It may also take your historical actions and requests into account. This type of automated decision-making is performed to draw conclusions about your interests to provide you with personally adapted content (so-called profiling). We may also use profiling to provide you with customized marketing.

You have the right to opt-out from our profiling features. This can be done either (i) by not consenting to other cookies than those necessary, (ii) by choosing your preferences when logged-in to your member account and (iii) by opting out from personalized marketing when logged-in to your member account.

5. Duration of data processing and storage

5.1 Data for the fulfilment of agreements

Personal data that we process for the purpose of negotiating, evaluating, entering, and fulfilling agreements with you or the company that you represent, is processed for as long as necessary for us to administer and fulfil the contractual relationship. If you have created a member account or purchase a Service through a one-off payment, we will process your data for as long as your member account is active or for the duration of time you have access to the purchased Service/Content. In certain cases, we will also process your personal data for a period after the agreement is terminated, for as long as necessary, for example during the period in which you or the party for whom you are the contact person and us, have or can bring legal claims against each other.

Please note that member accounts which have not been active or used for ten years will, unless you act upon our prior e-mail reminders, be deleted.

5.2 Data for legal claims

When we process personal data to exercise rights and fulfil our obligations in relation to you or the company/legal entity for which you are the contact person, we process your data during for the duration of such agreement or relationship and thereafter during the period in which you or the party for whom you are the contact person and us, have or can bring legal claims against each other. If you have participated in a recruitment process, we will store your personal data during the period where you may direct legal claims towards us with regard to the recruitment.

5.3 Data in order to send marketing material to you

The personal data that we process for the purpose of communicating business or product news and updates etc. will be processed for as long as you or the company that you are representing has a contractual relationship with us and for a certain time thereafter or (if our processing if based on your consent) if you have expressly consented to it or until you have withdrawn your consent.

Irrespective of whether you have given your explicit consent or not, you will always have the option of unsubscribing from such mailings at any time by contacting us (https://www.songally.com/contact) or by using the communications channel specified in the mailing. If you unsubscribe, the processing of your personal data for this purpose will cease.

5.4 For analysis and business development

Personal data that we process to analyze our customer base for the purpose of developing our business and providing our customers with updated, relevant, and improved offers is retained for as long as you or the company that you are representing have a contractual relationship with us and for a certain period thereafter or (if our processing is based on your consent) until you withdraw your consent.

5.5 Other

Songally may save your personal data for a longer period to comply with legal requirements or if Songally has the right to do so for the purposes referred to above. For example, personal data is saved in accounting documentation for at least seven (7) years after the calendar year in which the financial year ended.

6. Your rights

The GDPR involves a strengthening of the personal privacy and rights of the individual compared to earlier legislation. You have certain rights that you can exercise against us with regard to the processing of your personal data. You are welcome to contact us if you would like to exercise those rights. A brief description of your rights is provided below.

6.1 The right to withdraw your consent

If our processing is based on your consent, you may withdraw the consent provided in full or in part at any time with immediate effect from the withdrawal. However, the withdrawal will not have any effect on the processing that took place before the withdrawal of consent was notified. In case your withdrawn consent concerns our marketing, we may keep your contact details to make sure we do not send any marketing to you in the future.

6.2 The right to object to processing

You have the right to object at any time to the processing of your personal data that is based on a balance of interests. If we cannot show that we have legitimate reasons for the processing that outweigh your interest in not having the personal data processed, your personal data will no longer be processed for this purpose.

6.3 The right to limitation of processing

Under certain conditions, you have the right to request that the processing of your personal data may be limited. The right also exists if you have objected to the processing and we have not yet carried out verification of whether our legitimate interest outweighs your interest in not having the personal data processed.

6.4 The right to access

You have the right to know if we are processing your personal data and you have the right to access a copy of the personal data that we process. In the event of such a request, we must ensure your identity.

6.5 The right to rectification

You have the right to have inaccurate information corrected and to ask us to complete incomplete data. If you have a member account in any of our Services, you will also be able to correct and update your details there.

6.6 The right of erasure

Under certain conditions, you have the right to request us to erase your personal data. Please note that even though you exercise your right of erasure, we may have to keep processing some of your personal data, e.g., due to be compliant with applicable law.

6.7 The right to data portability

Under certain conditions, you have the right to require that your personal data is transferred in a structured, widely used and machine-readable format to another Data Controller. This right is limited to the data that you have provided to us.

6.8 The right to file a complaint

You have the right to file a complaint with a supervisory authority. It is beneficial for you to file such a complaint with the authority of the EU/EEA country in which you live or work. The supervisory authority in Sweden is the Swedish Authority for Privacy Protection (www.imy.se).

7 Contact details

To get in touch with us regarding our processing of your personal data or to invoke your rights, please contact us by email:

contact@songally.com or by post:

ProGuitar Sweden AB (Swedish reg# 559116-3638)

Laxholmstorget 3
SE-602 21 NORRKÖPING, SWEDEN

Mark the envelope with “Data Protection”.

8. Changes to our Privacy Policy

This Privacy Policy may be updated without notice at any time and the most recent edition is always available and published on our website and numbered a.

If we make material changes to the text, e.g. regarding changes to the purposes of processing your personal data, we will notify you before the change takes effect by publishing a new version on our website. If applicable, the change will also be sent by email, will be made available at our premises, and will be published on our websites.