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Privacy Policy

For Gayther.com, Care.Gayther and Gayther.lgbt
Gayther Featured - Privacy Policy

Below we set out our privacy policy which will govern the way in which we process any personal information that you provide to us. Gayther treats the personal information of users with the utmost respect and confidentiality and takes reasonable steps to ensure that your personal information is stored securely. The privacy policy should be read in conjunction with the general terms and conditions and affinity terms and conditions

BY USING OR ACCESSING OUR WEBSITES OR BY PROVIDING PERSONAL INFORMATION TO US ON OR THROUGH THESE WEBSITES, YOU CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF THAT INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND APPLICABLE LAW.

1. DEFINITIONS AND INTERPRETATION

1.1. In this privacy policy:
1.1.1 “we“, “Us” and “Our” means Ovester Limited registration number 06250776 trading as Gayther (and “us and “our” should be construed accordingly);
1.1.2 “you” means our website visitor, customer or prospective customer under this privacy policy (and “your” should be construed accordingly);
1.1.3 “website” means the website or any part thereof which is accessible from www.gayther.com, care.gayther.com or www.gayther.lgbt (and “site” should be construed accordingly);
1.1.4 “consent” means any voluntary, specific and informed expression of will in terms of which permission is given by or on behalf for the processing of your personal information;
1.1.5 “personal information” means any personal information or information relating to you used in relation to any services or sales used or acquired through the website, including but not limited to:
1.1.5.1 contact information such as name, email address, physical address, and contact telephone numbers;
1.1.5.2 session information such as your location information and IP address;

2. INTRODUCTIONS

2.1 We are committed to safeguarding the privacy of our website visitors and service users.
2.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
2.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
2.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls by selecting the “Privacy Preferences” button located within the Privacy Policy page on Gayther.com, Care.Gayther.com, or Gayther.lgbt
2.5 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

3. HOW WE USE YOUR PERSONAL DATA

3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent.
3.3 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
3.4 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“), The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
3.5 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.6 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.7 We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
3.8 We may process your website user account data (“account data“). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
3.9 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The source of the profile data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the profile data from the relevant social media account provider.
3.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.11 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.13 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4. PURPOSES OF PROCESSING AND LEGAL BASES

4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations – We may process your personal data for the purposes of operating our website and providing our services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
4.3 Publications – We may process account data, profile data and/or service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.
4.4 Relationships and communications – We may process contact data, account data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users, the maintenance of relationships, and the proper administration of our website, services and business.
4.5 Personalisation – We may process account data, service data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our website visitors and service users.
4.6 Direct marketing – We may process contact data, account data and profile data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
4.7 Research and analysis – We may process usage data and/or service data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
4.8 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
4.9 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
4.10 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.11 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.12 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

5. PROVIDING YOUR PERSONAL DATA TO OTHERS

5.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
5.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5.3 Financial transactions relating to our website and services are handled by our payment services providers, PayPal and Stripe. When selecting your preferred payment method you will directed to the payment services providers website. The information you share with the payment services provider is secure and not shared with us. The payment information required through our payment services providers are necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at PayPal or Stripe.
5.4 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).
6.2 We and our other group companies have offices and facilities in the United Kindgom. The competent data protection authorities have made an “adequacy decision” with respect to the data protection laws of each of these countries.
6.3 The hosting facilities for our website are situated in the United Kingdom. The competent data protection authorities have made an “adequacy decision” with respect to the data protection laws of each of these countries.
6.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

7. RETAINING AND DELETING PERSONAL DATA

7.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your personal data as follows:
(a) Usage Data will be retained for a minimum period of 12 months following the date you visited the website, and for a maximum period of 36 months following the date you visited the website;
(b) Enquiry Data will be retained for a minimum period of 36 months following the date the enquiry was received, and for a maximum period of 84 months following the date the enquiry was received;
(c) Transaction Data will be retained for a minimum period of 36 months following the date the goods or services were purchased, and for a maximum period of 84 months following the date the goods or services were purchased;
(d) Correspondence Data will be retained for a minimum period of 36 months following the date of the communication or when you visited the website, and for a maximum period of 84 months following the date of the communication or when you visited the website;
(e) Notification Data will be retained for a minimum period of 36 months following the date the request for email subscription or notification was received, and for a maximum period of 84 months following the date the email subscription or notification was received;
(f) Contact Data will be retained for a minimum period of 36 months following the date of the most recent communication between you and us, and for a maximum period of 84 months following that date;
(g) Account Data will be retained for a minimum period of 12 months following the date of closure of the relevant account, and for a maximum period of 26 months following that date; and
(h) Profile Data will be retained for a minimum period of 12 months following the date of deletion of the profile by you, and for a maximum period of 24 months following that date;
7.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of notification data will be determined based on the ongoing consent received from you.
7.5 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8. SECURITY OF PERSONAL DATA

8.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
8.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
8.3 The following personal data will be stored by us in encrypted form: your name and contact information.
8.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server or payment service provider, or from our web server or payment service provider to your web browser, will be protected using encryption technology.
8.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

9. AMENDMENTS

9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.3 We may notify you of changes to this policy by email.

10. YOUR RIGHTS

10.1 In this Section 10, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
10.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
10.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
10.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
10.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
10.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
10.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
10.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
10.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
10.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
10.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
10.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
10.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 10.

11. THIRD PARTY WEBSITES

11.1 Our website includes hyperlinks to, and details of, third party websites.
11.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

12. PERSONAL DATA OF CHILDREN

12.1 Our website and services are targeted at persons over the age of 18.
12.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

13. UPDATING INFORMATION

13.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

14. ABOUT COOKIES

14.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
14.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
14.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
14.4 Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.

15. COOKIES THAT WE USE

15.1 We use cookies for the following purposes:
(a) authentication and status – we use cookies to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website (cookies used for this purpose are: phpsessid); we use cookies to identify you when you visit our website and as you navigate our website,
(b) shopping cart – we use cookies to maintain the state of your shopping cart as you navigate our website (cookies used for this purpose are: eStore_gateway, cart_in_use);
(c) personalisation – we use cookies to store information about your preferences and to personalise our website for you (cookies used for this purpose are: gdpr(consent_types), gdpr%5Bprivacy_bar%5D, gadwp_wg_default_swmetric, wp-settings-1, wp-settings-time-1);
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose will be unique and will contain a combination of unique numbers and letters);
(e) analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: collect, _ga, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv, gadwp_wg_default_dimension, gadwp_wg_default_metric); and
(f) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: gdpr(allowed cookies)).

16. COOKIES USED BY OUR SERVICE PROVIDERS

16.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
16.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available by clicking here . The relevant cookies are: collect, _ga (term 2 years), _gid (term 24 hours), _gat (term 1 minute), __utma (term 2 years), __utmt (term 10 minutes), __utmb (term 30 minutes), __utmc (term session), __utmz (term 6 months) and __utmv (term 2 years).
16.3 We publish Google AdSense advertisements on our website, together with advertisements from the following advertisers and advertising networks that are distributed by Google: identify and provide links to advertisers and networks. The advertisements may be personalised to reflect your interests. To help determine your interests Google and its partners use cookies. The relevant cookies served from our website are 1P_JAR (term 30 days) and NID (term 6 months). The cookies are used to track your previous visits to our website and your visits to other websites. You can opt out of Google’s personalised advertising by visiting https://www.google.com/settings/ads and you can opt out of third party cookies use for personalised advertising by visiting http://www.aboutads.info. You can review Google’s privacy policy at https://policies.google.com/privacy.
16.4 We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook’s use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook’s use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.

17. MANAGING COOKIES

17.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
17.2 Blocking all cookies will have a negative impact upon the usability of many websites.
17.3 If you block cookies, you will not be able to use all the features on our website.

18. COOKIE PREFERENCES

18.1 You can manage your preferences relating to the use of cookies on our website by visiting: Gayther.com (https://gayther.com/privacy-policy), Care.Gayther.com (https://care.gayther.com/privacy-policy), or Gayther.lgbt (https://gayther.lgbt/privacy-policy) and by selecting the “privacy preferences” button found on the privacy policy page.

19. OUR DETAILS

19.1 This website is owned and operated by Ovester Limited trading as Gayther.
19.2 We are registered in England and Wales under registration number 06250776, and our registered office is at 2 Ambleside Avenue, London, SW16 6AD, United Kingdom.
19.3 Our principal place of business is at Gayther, 124 City Road, London, EC1V 2NX, United Kingdom.
19.4 You can contact us:
(a) by post, using the address Gayther, 124 City Road, London, EC1V 2NX, United Kingdom;
(b) using our website contact form;
(c) by telephone, on +44 (0)20 7043 9820; or
(d) by email, using info@gayther.com.

20. DATA PROTECTION REGISTRATION

20.1 We are registered as a data controller with the UK Information Commissioner’s Office.
20.2 Our data protection registration number is ZA383172.

21. DATA PROTECTION OFFICER

21.1 Our data protection officer’s contact details are:
Mr Peter Williams
Data Protection Officer
Ovester
124 City Road
London
EC1V 2NX
United Kingdom
Telephone:  +44 (0)20 7043 9820
Email:  dpo@ovester.com
If you have any questions in relation to the Privacy Policy, please contact us
IMPORTANT DISCLAIMER: The information displayed on this page is for illustrative purposes only and does not constitute advice. It is essential that before travelling that you independently establish information relating specifically to your requirements and circumstances. Though we endeavour to keep all information across the site updated, we do not guarantee the accuracy and completeness of any information displayed. The languages and terms featured on this page are literal translations and have not been validated or verified. The service is provided free of charge, and by using it, you accept that you are doing so at your own risk. This page may contain external links to third party websites; Gayther provides these links for your convenience and does not endorse, warrant or recommend any particular products or services. By clicking on any external links, you will leave Gayther and be taken to the third-party website, which you do so at your own risk and by accessing the site, you will be required to comply with the external third party’s terms and conditions of use and privacy policies