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1. Definitions
This privacy policy uses the terminology of the GDPR.
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); a natural person is deemed to be identifiable person, directly or indirectly, in particular by reference to an identifier such as a name, an name, to an identification number, to location data, to an online identifier or to one or more special characteristics which are an expression of the physical, physiological, genetic, mental, economic, cultural or social characteristics of the person, psychological, economic, cultural or social identity of this natural person.
Processing” shall mean any operation or set of operations which is performed with or without the aid of automatic such processing” means any operation or set of operations which is performed upon personal data, such as collection, recording, organization, organization, storage, adaptation or alteration, retrieval, consultation, use or disclosure, the storage, adaptation or alteration, retrieval, consultation, use, processing or disclosure of personal data, the disclosure by transmission, dissemination or any other form of making available, alignment or the linking, restriction, deletion or destruction.
“Restriction of processing” means the marking of stored personal data with the aim of, their restrict their future processing.
“Profiling” means any type of automated processing of personal data that consists of. personal data are used to evaluate certain personal aspects relating to a natural person, in particular aspects concerning natural person, in particular to evaluate aspects relating to work output, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or change of change of location of this natural person to analyze or predict.
“File system” means any structured collection of personal data that is accessible according to specified criteria criteria, regardless of whether the collection is maintained centrally, decentrally, functionally or geographical aspects.
“Responsible party” means the natural or legal person, public authority, agency or other body, who alone or jointly with others, determines the purposes and means of the processing of personal data where the purposes and means of such processing are determined by Union law or Member State law, the controller or Member State law, the controller or the specific criteria for its designation under Union law or designation may be provided for under Union or Member State law.
“Processor” means a natural or legal person, public authority, agency or other entity, which processes personal data on behalf of the controller.
“Recipient” means a natural or legal person, public authority, agency or other body to which personal data is disclosed, whether or not that person is a third party. or not. Public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law may receive personal data, however, shall not be deemed to be recipient; the processing of such data by the aforementioned authorities shall be carried out in accordance with the applicable data protection rules in accordance with the purposes of the processing.
“Third party” means any natural or legal person, public authority, agency or other body, other than the person concerned, the controller, the processor and the persons who, under the direct responsibility of the direct responsibility of the controller or processor, are authorized to process the process personal data.
“Consent” means the consent given by the data subject voluntarily for the specific case, in an informed manner and unambiguous manner, in the form of a statement or other unambiguous affirmative act by which the data subject indicates his or her affirmative act by which the data subject indicates that he or she consents to the processing of personal personal data concerning him or her.
2. Scope of application
The following data protection declaration applies to the Internet presence at purpose.app (hereinafter jointly referred to as the “Website”) of the Purpose GmbH (hereinafter referred to as “we” or “us”) with its registered office at Wilsnacker Str. 33, 10559 Berlin, Germany, represented by the managing director Julian Willner, application.
We are the responsible party for the processing of all personal data collected on the Website, unless otherwise stated in this Privacy Policy.
3. Data protection officer
You can reach our data protection officer at the following contact details: privacy@purpose.app
Purpose GmbH Wilsnacker Str. 33 10559 Berlin, Deutschland
4. Legal basis for the processing of personal data
Insofar as we obtain your consent for the processing of personal data, Art. Art. 6 para. 1 lit. a DSGVO serves as the legal basis.
When processing personal data that is necessary for the fulfillment of a contract with you. Art. 6 (1) lit. b DSGVO serves as the legal basis. This also applies to processing operations that for the are necessary for the implementation of pre-contractual measures.
Insofar as the processing of personal data is required for compliance with a legal obligation necessary to which our company is subject, Art. 6 para. 1 lit. c DSGVO serves as the legal basis. Very rarely may also be the case that vital interests of you or another natural person make a processing of personal data necessary. make the processing of personal data necessary. In these cases, Art. 6 para. 1 lit. d DSGVO serves as the legal basis.
If the processing is necessary to protect a legitimate interest of our company or of a third party and your interests, fundamental rights and freedoms do not outweigh our interest or the interest of a third party. interest of a third party, then Art. 6 para. 1 lit. f DSGVO serves as the legal basis for the processing. In these cases, our legitimate interest follows from the purposes of processing listed in this privacy policy. purposes of the processing.
5. Automatic collection of access data/server log files
We automatically collect a number of technical data each time you access the website. These are:
We process the aforementioned data for the following purposes:
6. User account creation and login
In the course of creating a user account (hereinafter referred to as “registration”) for our website you will be asked to enter a number of personal data (in particular title, first name, surname, e-mail address and possibly other data that we ask for during the registration process). These personal data is mandatory information and is required for the conclusion of the user contract. necessary. If you do not provide this data, you will not be able to create a user account. You can enter the data always view, change and delete the data via the menu item “User account”. It is also possible for you at any time delete the entire user account.
The mandatory data entered during registration will be processed and used by us to:
to authenticate yourself when you log in;
Follow up on requests to reset your password;
verify your authorization to manage the user account;
enforce the terms and conditions of use of the website and the services offered therein, as well as all related enforce rights and obligations, and
Contact you for technical or legal notices, updates, security messages or other messages concerning, for example, the administration of the user account.
This data processing is justified by the fact that the processing is necessary for the fulfillment of the contract between you as the data subject and us pursuant to Art. 6 para. 1 lit. b) DSGVO for the use of the services offered on our website services offered on our website, and/or we have a legitimate interest in ensuring the the functionality and error-free operation of our website and the services offered there, which is which here overrides your rights and interests in the protection of your personal data in the sense of of Art. 6 para. 1 lit. f) DSGVO.
7. Collection, processing and transfer of data based on your consent
On our website you can make use of various services. In this context, we collect and process certain information about you and your user and surfing behavior. The services of the website include the fact that we and our partner universities and companies, through the use of these services, such as Unifinder” and the profiling in the analysis, we as well as our partner universities and companies learn about your personality traits, aptitudes, and interests you have with regard to your studies and career and which information and offers from universities and companies are relevant for you in the context of our target group, so that are relevant for you, so that:
we can show you relevant study offers from universities and promotional offers from partner companies;
we, universities and partner companies can conduct market research on the basis of anonymized data as well as for analysis and marketing purposes.
The collection and processing of usage data takes place for the provision of the services. The collection and processing of the data is justified by the fact that the collection and processing is necessary for the fulfillment of the of the contract between you as the data subject and us pursuant to Art. 6 para. 1 lit. b) DSGVO for the use of the services. on our website is necessary. The processing of data for market research, analysis and marketing purposes is in this respect a main service. The legal basis for the disclosure and transfer of the data is, in addition to the legal bases mentioned in § 8, your consent, Art. 6 para.1 lit. a) DSGVO. In addition we have a legitimate interest in the data processing within the meaning of Art. 6 para. 1 lit. f) DSGVO. Since you are free to use the services on our website and we also provide detailed information about the collection, processing and disclosure of usage data, our legitimate interest outweighs your rights and freedoms. your rights and freedoms.
NOTICE:
In this respect, we would like to point out once again in all clarity that the meaning and purpose of our services also includes the evaluation of your user and surfing behavior under processing of your data, in order to use these data for the purpose of market research, analysis, advertising and marketing. Marketing includes in particular the referral of the user of the services on our website to partner universities and -companies and the interaction with advertising material provided by them on our website and through links. provided.
8. Disclosure of data without your consent
A passing on of your personal data without your express previous consent takes place in addition to explicitly mentioned in this privacy policy only if it is legally permissible or required. or required by law. A technical transfer may also take place if and insofar as this is necessary for the operation of our website and the services offered there. operation of our website and the services offered there or for other reasons for the justification, the implementation or processing of your user relationship with us. This can be for example the This may be the case, for example, if we host the website with an external service provider. Provided that this is not processing, the transfer is based on Art. 6 para. 1 lit. b) DSGVO.
Irrespective of your consent as stated in § 7, we will disclose your personal data, such as e.g. your advertising ID also out of legitimate interest within the meaning of Art. 6 Para. 1 lit. f) and on the basis of the user contract concluded with us contract of use concluded with us pursuant to Art. 6 para. lit. b) DSGVO to our partner universities and -companies out. Since we offer the services on our website free of charge, we have a legitimate interest in the use of marketing measures. This interest also outweighs the interests of the user, as it user is free to decide whether to use our website and participate in the analysis and other services. would like.
If it is necessary to clarify an illegal or improper use of the website and the services offered there, or for legal services offered there or for legal prosecution, personal data will be passed on to the law enforcement agencies or other authorities and, if necessary, to injured third parties or legal advisors. forwarded. However, this will only happen if there are indications of illegal or abusive behavior. abusive behavior. A transfer may also take place if this serves the enforcement of terms of use or other legal claims. We are also legally obligated, upon upon request to provide information to certain public authorities upon request. These are law enforcement agencies, authorities that prosecute prosecute administrative offenses subject to fines, and the tax authorities. Any disclosure of the personal data is justified by the fact that the processing is necessary for compliance with a legal obligation to which we are subject pursuant to Art. 6 Para. 1 lit. f) DSGVO in conjunction with national legal national legal requirements for the disclosure of data to law enforcement authorities, or we have a legitimate have a legitimate interest in disclosing the data in the event of indications of abusive behavior or to enforcement of our terms of use, other terms and conditions, or legal claims, and to protect your rights. third parties and to protect your rights and interests in the protection of your personal data within the meaning of Art. of Art. 6 para. 1 lit. f) DSGVO.
As part of the further development of our business, the structure of our company may change. legal form is changed, subsidiaries, parts of companies or components are founded, bought or sold. or components are founded, bought or sold. In such transactions, customer information customer information may be transferred along with the part of the business being transferred. In any transfer of personal information to third parties to the extent described above, we will ensure that it is ensure that this is done in accordance with this privacy policy and applicable data protection law. applicable data protection law. Any disclosure of personal data is justified by the fact that we have a legitimate interest in adapting our corporate form to the economic and legal circumstances as legal circumstances and to protect your rights and interests in the protection of your personal data within the meaning of Art. personal data within the meaning of Art. 6 para. 1 lit. f) DSGVO.
9. Forwarding to third parties
On our website and the services offered there can, by clicking on external links, redirections to third parties. This will leave our website and third parties independently responsible for responsible for data processing
10. Contact
When contacting us (for example, by contact form or e-mail), your information will be stored for the processing of the request and in the event that follow-up questions arise, stored.
11. Newsletter
On the website you can subscribe to a newsletter, in which we inform about new features, offers and and other promotions. With the subscription to the newsletter, we store your IP address and the date of the subscription. This storage serves solely as evidence in the event that a third party misuses a e-mail address and registers for the newsletter without the knowledge of the authorized person. This data will only be used for sending the newsletter and will not be passed on to third parties.
You can revoke your consent to the use of your e-mail address for sending the newsletter at any time. revoke. The revocation can be done via a link in the newsletters themselves or by sending a message to the contact options in the imprint of the website.
We would like to point out that we evaluate your user behavior when sending the newsletter. For this evaluation, the e-mails sent contain so-called web beacons or tracking pixels, which are single-pixel pixel image files that are stored on our website. Also in the newsletter received links received in the newsletter also contain this ID. For the evaluations, we link your personal data already collected by us in § 5 (data transmission during a mere visit to our website) and the web beacons with your e-mail address and an individual ID. With the data obtained in this way, we create a user profile in order to tailor the newsletter to your individual interests. In doing so, we record, when you read our newsletter, which links you click on in the newsletter, and use this to infer your personal interests. We link this data to actions you have taken on our website. You can you can object to this tracking at any time by clicking on the separate link provided in each e-mail or by in every e-mail or by informing us via the e-mail address given in the imprint. The information will be stored for as long as you are subscribed to the newsletter. After an unsubscription we store the data purely statistically and anonymously. Furthermore, such tracking is not possible if you have deactivated the display of images by default in your e-mail program. In this case, the newsletter In this case, the newsletter will not be displayed in full and you may not be able to use all functions. If you go to display the images manually, the above-mentioned tracking will take place.
12. Cookies
Cookies are small text files that are stored on your end device by the browser used when you call up our website. browser used when you call up our website. Individual services of a website can use this way “recognize” you and “remember” which settings you have made. This serves on the one hand the user-friendliness of our website (e.g. storage of login data). On the other hand, cookies serve to collect statistical data on website use and to use the data thus obtained for analysis and advertising purposes. advertising purposes.
Cookies are small text files that are stored on your end device by the browser used when you call up our website. browser used when you call up our website. Individual services of a website can use this way “recognize” you and “remember” which settings you have made. This serves on the one hand the user-friendliness of our website (e.g. storage of login data). On the other hand, cookies serve to collect statistical data on website use and to use the data thus obtained for analysis and advertising purposes. advertising purposes.
You can influence the use of cookies. Most browsers have an option with which which the storage of cookies is limited or completely prevented. However, we must point out point out that the use of our services and in particular the comfort of use without cookies is limited is limited.
13. Facebook Benutzerdefinierte Zielgruppen, Facebook Pixel
In order to make you interesting offers related to you, we transmit your data encrypted and anonymized to Facebook. anonymized to Facebook – so we can help even more students and high school graduates to find their find their dream study. This way, our ads are displayed to those who are interested in them. For For this procedure, which is very common in marketing, we use “Facebook Custom Audiences”. In this process, we do not give name, email and personal information to Facebook in plain text, but upload it in encrypted form. but upload them in encrypted form. This ensures that no third parties can access your data and that you will not be and that you will not suffer any disadvantage.
Due to the marketing tools used, your browser automatically establishes a direct connection with the Facebook server. We have no influence on the scope and further use of the data, which collected by Facebook through the use of this tool and therefore inform you accordingly. our state of knowledge: Through the integration of Facebook Custom Audiences, Facebook receives the information that you have called the website of our website or that you have clicked on one of our advertisements. clicked. If you are registered with a Facebook service, Facebook can associate the visit with your account. to your account. Even if you are not registered with Facebook or have not logged in, there is the possibility, that the provider learns and stores your IP address and other identifying features. Deactivation of the “Facebook Custom Audiences” function is possible for logged-in users at https://www.facebook.com/settings/?tab=ads possible. Further information on data processing by Facebook is available at https://www.facebook.com/about/privacy.
We also use the so-called “Facebook Pixel” to create Facebook Custom Audiences. When you visit our website and also when you perform certain actions, the Facebook Pixel is is triggered and the visit or action is reported anonymously to Facebook and registered by Facebook. Based on the collected data, Facebook can tell us how successful our website is. In a second step, it is also determined for which user groups which of our offers are interesting. These groups can then be re-advertised by us as potentially interested parties, this is called “remarketing”. “remarketing”.
By submitting the declaration of consent when creating your user account, you agree to the data processing by us via “Facebook Custom Audiences”. You can revoke this consent with effect for the future at any time by informing us of your revocation, e.g. at the e-mail address given in the imprint. e-mail address given in the imprint.
14. Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Information of the third party provider: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. user terms: http://www.google.com/analytics/terms/de.html, Overview to the Data protection: http://www.google.com/intl/de/analytics/learn/privacy.html as well as the privacy policy: http://www.google.de/intl/de/policies/privacy.
Google Analytics sets several cookies named in § 12 to identify your browser. The cookies set by the information generated by the cookies about your use of this website is usually sent to a server of of Google in the USA and stored there. However, we have activated the IP anonymization function on this website. this website, so that your IP address is not stored by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. before shortened. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. For the exceptional cases in which personal data is transferred to the U.S., Google has Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 para. 1 p. 1 lit. f DS-GVO.
On our behalf, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity. compiling reports on website activity and providing other services relating to website activity and internet usage. Internet use to provide services to the website operator. The data collected in the context of IP address transmitted by your browser in the context of Google Analytics will not be merged. You can also refuse the transfer of data generated by the cookie and related to your use of the website (including your IP address). your use of the website (including your IP address) to Google and the processing of this data. data Google by downloading and installing the browser plugin available at the following link. installing it: http://tools.google.com/dlpage/gaoptout?hl=de.
This website also uses the Google Tag Manager. The Google Tag Manager is a kind of user management for our IT department. user management for our IT department, with which e.g. a link with Google Analytics can be more easily can be managed more easily.
15. DoubleClick by Google
This website continues to use the online marketing tool “DoubleClick by Google”. DoubleClick uses in § 12 to serve ads that are relevant to users, to improve campaign performance reports, or to prevent users from or to prevent a user from seeing the same ads more than once. Via a cookie ID, Google records which ads are served in which browser and can thus prevent that be displayed more than once. In addition, DoubleClick can use cookie IDs to record so-called conversions which are related to ad requests. This is the case, for example, when a user sees a DoubleClick ad and later accesses the advertiser’s website with the same browser and there makes a purchase. According to Google, DoubleClick cookies do not contain any personal information.
Due to the marketing tools used, your browser automatically establishes a direct connection with Google’s server. Google server. We have no influence on the scope and further use of the data collected by Google. collected by Google through the use of this tool and therefore inform you according to our knowledge. state of knowledge: By integrating DoubleClick, Google receives the information that you have visited the corresponding part of our website. of our Internet site or clicked on an ad from us. If you are registered with a service of Google, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, there is a possibility that the provider learns about and stores your IP address and stores it. Google has subjected itself to the EU-US Privacy Shield and thus thus guarantees compliance with the EU data protection standard. Further information about DoubleClick by Google is available at https://www.google.de/doubleclick, as well as on data protection at Google in general: https://www.google.de/intl/de/policies/privacy
The legal basis for the processing of your data is Art. 6 para. 1 p. 1 lit. f DS-GVO. You can prevent the participation in this tracking process in various ways:
by adjusting the settings of your browser software accordingly, in particular the suppression of In particular, the suppression of third-party cookies means that you will not receive any ads from third-party providers;
by deactivating the cookies for conversion tracking by setting your browser to block Cookies from the domain “www.googleadservices.com” are blocked, https://www.google.de/settings/ads, whereas this setting is deleted when you delete your cookies;
by deactivating the interest-based ads of the providers that are part of the About Ads” self-regulatory campaign via the link http://www.aboutads.info/choices, whereas this setting is deleted when you delete your cookies;
by permanently deactivating it in your Firefox, Internet Explorer or Google Chrome browser under the link http://www.google.com/settings/ads/plugin.
We would like to point out that in this case you may not be able to use all functions of the services on our website. on our website to the full extent.
16. Hotjar
We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.
For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
17. General advertising opt-out
The following link will take you to the Digital Advertising Alliance website. Here you can declare a general opt-out can be declared for various online advertising technologies. A German-language alternative to the Digital Advertising Alliance can be found here: http://www.meine-cookies.org/cookies_verwalten/praeferenzmanager-beta.html
18. Change of purpose
Processing of your personal data for purposes other than those described above will only take place insofar as a legal provision permits this or you have consented to the changed purpose of the data processing. In the case further processing for purposes other than those for which the data was originally collected, we will inform you about these other purposes prior to further processing and provide you with all further relevant information for this purpose.
19. Duration of the storage of your data
We store personal information only for as long as necessary to perform the services that you services you have requested or for which you have given your consent, or as long as the purpose of the data purpose of the data processing, taking into account your interests, unless otherwise required by law. legal obligations exist.
20. Protect your data
In order to protect your data from manipulation, loss and unauthorized access by third parties, for example, we use technical and organizational measures to ensure an adequate level of protection of your personal data. level of protection. These measures include, among other things, the use of firewalls and antivirus programs as well as manual security precautions. We review and improve our security measures on an ongoing basis in line with the current state of the art. In addition, in accordance with the principle of “data protection through In addition, in accordance with the principle of “privacy by default”, the strictest privacy settings are already preset when you first log in.
21. SSL encrypted data transmission
Your personal data is transmitted in encrypted form to prevent misuse by third parties. We use a so-called SSL encryption (Secure Socket Layer) for this purpose. It This is a common security technology that protects your personal data, including your login and password. and analysis data during transport. Please note that when transferring data over the Internet, no cannot be guaranteed to be 100% secure when transferring data over the Internet.
22. Your rights as a data subject
Right to information: You have the right to request information from us at any time about the personal data we processed personal data concerning you within the scope of Art. 15 DSGVO. For this purpose you can submit a request by mail or e-mail to the address below.
Right to rectify inaccurate data: You have the right to obtain from us the rectification without delay of the you personal data concerning you if it is incorrect. To do this please use the contact addresses below.
Right to erasure: You have the right, under the conditions described in Art. 17 DSGVO, to request from us the to request deletion of the personal data concerning you. These conditions provide in particular a right to erasure if the personal data is no longer necessary for the purposes for which it was collected or otherwise processed, as well as in cases of unlawful processing, the existence of an objection to the processing, the existence of an objection or the existence of an erasure obligation under Union law or the law of the Member State to which we are subject. For the period of data storage, please refer to Section 6 of this privacy policy. To assert your right to erasure, please contact the contact addresses given below.
Right to restriction of processing: You have the right to obtain from us the restriction of processing according to in accordance with Art. 18 DSGVO. This right exists in particular if the accuracy of the personal data is disputed between the user and us, for the period of time required to verify the of the accuracy, as well as in the event that the user, in the case of an existing right to erasure instead of deletion instead of deletion; furthermore, in the event that the data is not required for the purposes for which us purposes pursued by us, but the user requires them for the assertion, exercise or defense of legal claims, as well as when the successful exercise of an objection between us and the user is still in dispute. To exercise your right to restrict processing, you may exercise it, please contact us at the contact addresses below.
Right to data portability: You have the right to obtain from us the personal data concerning you, you have provided to us in a structured, commonly used, machine-readable format in accordance with the of the Article 20 DSGVO. To exercise your right to data portability, please contact. the contact addresses below.
Right to object: You have the right to object on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you, which is carried out, among other things, on the basis of Art. 6 Paragraph 1 lit. e) or f) DSGVO, to object in accordance with Art. 21 DSGVO. We will stop the processing of your personal data, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or if the processing serves the assertion, exercise or defense of legal claims. In the event of objection you can you will no longer be able to use the services on our website. You can object to the processing of your personal data at any time by sending a e-mail to privacy@purpose.app. contact details given in the imprint. The use of the services on our website is no longer possible after the objection. more possible.
Right to revoke consent: If you have given us consent to data processing, you can revoke this consent at any time in the future by sending a e-mail to privacy@purpose.app. The Use of the services on our website is no longer possible after the revocation.
Right to complain: You have the right to contact the competent supervisory authority in case of complaints. A list of supervisory authorities can be found here: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.htm
23. Actuality and change of this privacy policy
You can access and print out the current privacy policy at any time on our website.
Due to the further development of our website and the services offered there or due to changed legal or legal or regulatory requirements, it may become necessary for us to amend this data privacy statement. change. Therefore, we reserve the right to change this privacy policy at any time with effect for the future. to change. We will inform you in an appropriate manner via the website or by e-mail about the change of the Privacy Policy with reasonable advance notice (at least 6 weeks). You will be given the opportunity to object to the change by e-mail to the e-mail address indicated in the respective imprint of the website. contradict. If you exercise your right of objection, we are entitled to delete your user account with effect from the time the effective as of the date on which the change takes effect. Any backup of data is your sole responsibility.
Current valid status: 06/01/2022