Penguin Holiday Privacy Policy

Penguin Holiday Limited (“Penguin Holiday NZ”) takes its data protection and privacy responsibilities seriously.

 

Please read the following privacy policy (Privacy Policy) to understand how we use and protect the personal information you provide to us, or we receive and collect when you use our services, including how we collect it, and what we do with it, as well as some of the steps we take to safeguard your personal information. We hope that this will help you make an informed decision about sharing personal information with us.

 

This Privacy Policy may be updated from time to time to keep it up to date with legal requirements and the way we operate our business. You are responsible for reviewing this Privacy Policy periodically and informing yourself of any changes to this Privacy Policy. We suggest that you check back regularly to review any changes. If we make significant changes to this Privacy Policy, we will seek to inform you by notice on our website or email.

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Penguin Holiday NZ Company

Penguin Holiday Limited is a fully NZ owned company, and references to “we”, “our” and “us” mean Penguin Holiday. You can find out more about us on social media https://www.instagram.com/penguinholidaynz/ 

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For the purposes of relevant data protection laws (including each of the EU and UK General Data Protection Regulation (EU/UK GDPR), Penguin Holiday NZ will be the primary controller of your personal data.

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This is Penguin Holiday NZ’s principal external facing privacy notice and it applies to all persons whose personal information is processed by Penguin Holiday NZ. "This Privacy Policy applies not only to our interactions with customers, suppliers, and business partners, but also to all information collected through our website www.penguinholiday.com, other websites, mobile apps operated by Penguin Holiday NZ, and any online platforms where we provide travel-related services—including partner websites and social media channels."

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However, you should also review the online policies of the company that you engage with, where they may have separate notices on how they protect your information to satisfy yourself as to the way in which they process and handle your personal data.

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What Information do we collect about you?

Making an Enquiry or Booking a Trip

We will collect certain information from you when you make an enquiry or book a trip with us. Depending on your interaction with us and what products and services you use, typically we collect the following personal information:

• your full name, date of birth, gender (i.e. male/female/other), title, postal address, phone number, email address, next of kin, dietary requirements, height and weight, travel insurance details, passport details (including nationality and city of birth), passport scan, visa application, visa page scan;

• we may also ask for medical / health information, such as pre-existing medical conditions, if you have a disability, medication that requires refrigeration, food allergies etc., some of which is considered sensitive information or special category data under relevant data protection laws; and

• any additional information you provide during the booking process to check if a trip is right for you, which may include personal information.

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We also process and store records of the products and services you have enquired about or purchased from us, as well as collect and process information relevant to your booking (such as flights and accommodation details) that you have not booked through Penguin Holiday NZ, where this information has been passed to us by our partners and/or third parties.

We also collect your technical identity data (including IP addresses, browser type and versions, other technology on the device that you use to access our websites, some of which is collected automatically), as well as information about your usage of our websites as you and others browse our websites (see our separate “Cookies” policy for more information).

We may also receive information about you from other sources. These include business partners, such as our affiliate partners, travel providers and tour operators, travel agents and other independent third parties. Anything we receive from these sources may be combined with information provided by you. For example, our services are not only made available via our website and mobile apps, but are also integrated into the services of our affiliate partners that you can find online. When you use any of these services, you may provide reservation details to our business partners who, where permitted, then forward your details to us.

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Travel providers (e.g. accommodation, hotel, transport and other similar local providers (Travel Providers) may also share personal information about you with Penguin Holiday NZ, for example, to ensure fulfillment of your travel reservation, if you have support questions about a tour or trip booked, or if any complaints or disputes arising about your reservation.

Through your user preferences on your Penguin Holiday NZ booking account, if you link your Penguin Holiday NZ user account to a social media account (e.g. Facebook or Twitter) you may exchange information between us and that social media provider – though you can at all times choose not to share that data through the user preferences on your account.

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Financial Information

We also integrate with third party service providers (such as Flywire, Stripe) and payment gateways (such as Stripe) to facilitate payments between you and us and our partners and tour operators and agents, as applicable. These service providers share payment information so we can administer and handle your travel services reservation or tour. All of our third-party payments providers are required to be PCI DSS compliant and process all payments on our behalf.

In the majority of cases, to make a payment via credit card for your tour / travel services, you will use the secure online booking engine on the relevant website or platform that you are using or you will call your booking agent directly. In some limited cases you may provide us with your credit card details over the phone; for example if Penguin Holiday NZ needs to provide you with a refund, your bank details may be collected and recorded by us for the purposes of providing the refund only.

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We ask that you do not email or send in writing your payment card details to us or any of our partners at any time.

We are not responsible for the privacy practices of third-party vendors and providers, including payment providers, so you should review any privacy policy of third party vendor or providers to satisfy yourself as to how they protect and handle your personal information.

With your consent also, any calls with us, if any, may be recorded, and/or monitored for quality control, coaching and/or training and customer service purposes that assist in addressing your inquiries. As part of the recording we may collect information such as the identity of the caller, the date and time of the call and the subject and resolution of the issue. For clarity, any financial information that may be provided during a telephone call is not recorded or logged by Penguin Holiday NZ.

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Photo and Video

When you are travelling with us on a tour or branded trip, as part of your experience a photo or video may be taken either by the Penguin Holiday NZ group leader, an employee of Penguin Holiday NZ or one of our partners or another passenger. We care about your privacy so if you do not wish for your photograph to be taken at any time, or to be included in any video, please let your tour group leader or the photographer know. Any photos taken by Penguin Holiday NZ staff (including employees and group leaders) will not be used for marketing purposes without your prior knowledge. Whilst we take every precaution to protect your privacy, we are not responsible for passengers who may take your photograph or video you without our knowledge.

On some occasions, we may engage professional photographers to take and obtain photos to use in our marketing materials. We ensure that all of our customers are notified prior to travelling on our trips if a professional photographer is being engaged and you have the right to say no or opt-out of being included in any photos being taken for these purposes, including any subsequent content or images use.

Marketing and Other Interactions

We collect the following personal information from you for marketing purposes (as more fully described below):

• when you subscribe to the newsletter, we will collect your full name, country and email address

• via our preference centre, we will collect your phone number, date of birth, postcode/zip code, residential state and your travel preferences

• if you request a brochure, we will collect your full name and email

• if you enter a competition directly with Penguin Holiday NZ, or via one of Penguin Holiday NZ’s external partners, or click through on a Penguin Holiday NZ advertisement, we may collect your full name, country, zip code, email address and phone number, as well as your travel preferences.

• when you click on a Penguin Holiday NZ advertisement via a third party, some of this information may pre-populate from an account you may have with that third party.

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Research

We may contact you to seek your interest in taking part in research projects, surveys, feedbacks and interviews. This may include contacting you with a post-booking or post-trip feedback survey and asking to provide a score and comment on your experience.

As part of this contact, we may collect your full name, email address, booking number and departure code. You will be asked to provide a score and comment on your trip experience. This information will be linked to any comments you make about your trip.

Where you have provided the relevant details, we may also contact you in response to your feedback to discuss your comments.

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Job Applicants

If you apply for a job with us, we will collect your CV details and supporting documents which include personal information. We will also request you fill in a form and will ask for your personal information, where necessary, such as your full name, contact details, home address, date of birth, sex, ethnicity (optional), accessibility requirements and details in relation to your passport and immigration information.

Why do we collect your information?

We collect, hold and handle your personal information for a variety of business purposes (further information on each of which is set out below), including to:

• provide you with our and our partner travel products and services, administer your reservations and tours, manage your booking account settings (if you open a Penguin Holiday NZ user account), and generally administer and manage our customer relationship with you;

• if you are a business partner, supplier or agents, to manage our business relationship with you;

• contact you and process your communications with us, for example, to respond to your queries or complaints, or if we need to tell you something important, or invite you to complete a booking (e.g. if started but not finished a tour reservation online);

• generally improve our products and services and your user experience with us;

• comply with our legal obligations and assist government and law enforcement agencies or regulators; and

• carry out our marketing activities, including identify and tell you about other travel related products or services that we think may be of interest to you, process feedback forms and other similar communications.

 

Under applicable privacy and data protection laws (including EU/UK GDPR), for Penguin Holiday NZ to collect, hold, use, share and process your information we must have a purpose and legal basis to do so. The legal basis may differ depending on your interaction with us and what information we collect and process, which will fall under:

Necessary for the performance of a contract – When you make an enquiry or book a trip with us or any of our partners, we rely on the legal basis that the processing of your personal information is necessary for the performance of your contract with us i.e. completing a travel reservation as part of your planned itinerary and administering your booking.

 

Legitimate Interest – Our legitimate interest means your information has a commercial business purpose and is necessary in order to provide a product or service to you and does not override your rights and freedoms as an individual. For example as a travel customer, we collect your email address for the purpose of communicating with you when necessary to communicate about the product or service you’re requesting or booking, and for Penguin Holiday NZ to provide you with relevant information. If you are a business partner, we may process your contact information in order to manage our relationship with you. We also rely on our legitimate interests to improve our products and services, and to prevent fraudulent activity on our online platforms and accounts (as set out more specifically below). When using personal data to serve our or a third party's legitimate interest, we will always balance your rights and interests in the protection of your personal information against our rights and interests or those of the third party, including by using your information in a way which is proportionate and respects your privacy.

Legal Obligations - in certain circumstances we will need to use your information to comply with our legal obligations, for example, to comply with local laws in the country you are visiting.

Vital Interest – we rely on the legal basis of vital interest in certain limited circumstances where it is essential to you and your health that we process your personal information; for example, to contact medical providers / insurance providers in the case of any medical emergency.

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Consent – where required by applicable laws, we will obtain your prior consent prior to processing your personal information, including before sending you electronic marketing materials or as otherwise required by law.

You can revoke your consent or object to our marketing in certain circumstances; please see ‘What are your rights’ for further information.

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Providing your personal data to us is voluntary. However, we may not be able to fulfil your reservation and your experience may be affected if certain personal information is not provided. We may only be able to provide you with some products and services if we can only collect some personal data. For example, we can’t process your travel booking if we don’t collect your name and contact details.

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Making an Enquiry or Booking a Trip

We use your personal information to arrange and provide you with the products and services you have requested and booked. This includes booking any flights, transportation, accommodation and activities. The following will provide more insight into these purposes:

• Your personal information will be used by our group leaders to identify you and ensure your safety during the trip.

• Depending on your destination and services being booked for you, we may be required by the supplier to provide certain types of personal information in order to secure the booking. We may also be legally required by local laws and governments to provide travel documentation such as passport details or a passport scan.

• Your contact details will be collected in order to manage our relationship with you, including updates about your booking, providing relevant information and any applicable tickets, handling feedback and complaints, and to contact you in the event of an emergency.

• Providing relevant information, which may include sensitive information, to insurance providers, their agents and medical staff in circumstances where we/they need to act on your behalf or in the interest of passengers or in an emergency.

• Where permitted by law, where it is in your vital interest or you provide your consent to do so, your medical/health information may be shared to ensure that we understand any specific needs you may have, before and during your trip. Any pre-existing medical conditions could impact your enjoyment of the trip, and by informing us of any conditions, issues or limitations, we can ensure that Penguin Holiday NZ is better prepared to assist if required.

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Other than where it is in your vital interests or required by relevant laws, medical/health information can only be used by Penguin Holiday NZ with your consent. This is because medical/health information is considered sensitive and by consenting, you are showing us that you understand and agree to us processing this information. Providing medical/health information and consenting to its use by Penguin Holiday NZ is optional, however, it is highly recommended that information be provided (including if requested) for your safety and wellbeing.

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Photo and Video

Many people enjoy taking photos or videos to capture meaningful moments, which is why you might appear in visual media during your trip. Sometimes, images or videos taken by Penguin Holiday NZ staff or group leaders are of such high quality that our Studio team may want to feature them in promotional materials like brochures or our website. Additionally, a professional photographer may be present on your trip specifically to capture images for promotional use. In such cases, you’ll be given a consent and waiver form. Signing this form is completely optional, and you are not required to provide your consent. We are committed to respecting your privacy and will honor your preferences regarding any personal information collected through visual media.

 

Marketing and Other Interactions

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Penguin Holiday NZ may use your information for marketing purposes including:

• to identify and tell you about Penguin Holiday NZ’s products and services we think you may be interested in;

• to offer you deals on partner products and services;

• to tell you about trip deals, discounts and promotions; and

• to administer promotions, feedback surveys and the like;

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These products and services may be offered by us, our associated companies, or our brand partners.

We will only engage in direct marketing in accordance with the laws of the relevant country or jurisdiction you are located in.

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Marketing and Privacy Preferences

To respect your privacy and give you control over how we communicate with you, we limit our direct marketing to a reasonable and relevant level. We’ll only send messages we believe are of genuine interest, based on the products or services you’ve purchased or shown interest in. If you receive marketing emails from us, you can opt out at any time by following the unsubscribe link at the bottom of the message. You can also manage your preferences through your account settings or by contacting us at sales@penguinholiday.co.nz.

You can adjust your browser settings to manage how cookies are used, including those used for online advertising. We also recommend reviewing your privacy and ad preferences on any social media platforms you use, as well as within your account with us.

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Research and Service Improvement

We use customer feedback, comments, and other data to better understand your needs and enhance your overall experience. This helps us improve our services, tailor online content, and refine our website and booking process. We also analyse trends to develop new destinations and travel offerings.

De-identified data may be used for internal reports, marketing strategies, and to track the success of partnerships. Occasionally, we may invite you to take part in surveys, interviews, or research projects to learn more about your preferences, travel habits, and expectations. Any information collected may be stored for future reference and will be anonymized where appropriate.

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Job Applicants

Information collected from job applicants will be used to process your application, decide if you are right for the role you are applying for and for us to communicate with you. We will also use your de-identified information to analyse and understand who is applying for our jobs, understand where barriers might exist and to improve our job offerings and recruitment processes in future.

If you are successful in your application, the details you have provided to us will be transferred through to our Human Resources system to begin building your employee profile.

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How do we collect your information?

We may receive your information in several different ways. You might share it directly with us or through our sales representatives, travel agents, business partners such as tour operators and guides, or other third parties like insurance or medical providers—whether by email, phone, letter, web chat, or in person. You could also provide your details by completing an online or paper form, submitting feedback, taking a survey, or signing up for a newsletter or loyalty program.

Additionally, a friend or family member booking on your behalf may also supply your information to us.

Sharing your information

Making an Enquiry or Booking a Trip

In order to handle your enquiry, fulfil your product or service request or manage your booking, we may share your personal information with the following:

• any member of Penguin Holiday NZ and our internal contractors and staff, including local group leaders;

• our related overseas entities and destination management companies

• our network and branded partners (e.g. travel agencies, tour operators etc.).

• travel providers (e.g. Airlines, tour companies);

• other third-party operators (i.e. local operators, couriers, mailing houses, payment processors, etc.);

• other suppliers and service providers (e.g. hotels, transfer drivers, etc.); and

• in some cases, Government authorities (e.g. for border crossings, visa requirements.)

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Sharing of Personal Information

For transparency, when you book flights through Penguin Holiday NZ, or if your trip includes flights, your relevant personal details will be shared with the appropriate airline. Similarly, if your trip is operated by a third-party tour company not affiliated with Penguin Holiday NZ, we will share your information with them so they can confirm your booking and deliver the necessary services. Your personal data may also be shared with travel providers and local third-party operators to enhance service quality, ensure a smooth experience, or assist in resolving complaints or disputes when needed.

We strongly encourage you to review the privacy policies of all travel providers and tour operators involved in your trip. Penguin Holiday NZ is not responsible for the privacy practices of third-party service providers you may choose to book with.

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Support Services and Third-Party Partners

To deliver, improve, and support our services, we may share your personal information with trusted third-party providers, including:

• IT Service Providers: These partners help with website and app development, hosting, maintenance, data backup, storage, technical support, troubleshooting, payment processing, and analytics. Access to your information is only granted where necessary to perform their duties.

• Marketing Partners: We collaborate with a global network of marketers who assist in promoting our services, generating leads, providing sales support, and sending marketing materials on our behalf.

• Research and Analytics Providers: We may work with research firms to conduct surveys, interviews, and data analysis to better understand customer needs and improve our services.

We ensure that these third parties are bound by confidentiality agreements and that your information is only used for the specific purpose of delivering services on our behalf.

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Other Information Sharing

We may disclose or transfer your information in the event of a business merger, sale, acquisition, or similar corporate transaction. In such cases, we will notify you via email and/or a prominent notice, along with any available options regarding your data.

We may also share personal information with:

• Regulatory bodies (including international privacy regulators and supervisory authorities), courts, or law enforcement agencies to comply with legal obligations or government requests.

• Insurance providers or medical professionals for purposes such as fraud detection, legal compliance, or in cases involving potential threats to life, health, or safety.

• Advertisers, in the form of aggregated, anonymized data (e.g. website traffic or usage trends) that does not personally identify individuals.

Selling data

We do not and will not sell your personal information under any circumstances.

Cross-Border Transfers

As we have stated earlier, it is necessary for us to share your information with our Group entities, partners and third parties, many of which are located overseas. When we transfer your information overseas, we seek to ensure appropriate privacy, confidentiality and security measures are in place, and that we comply with all applicable data protection and privacy laws.

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Further, Penguin Holiday NZ operates with different service providers in over 6countries, across all regions of the world, so it is not possible for us to provide a list of all these countries in this Policy. If you have any specific questions about where or to whom your personal information will be sent, please contact sales@penguinholiday.co.nz

In some jurisdictions, including the EEA, the UK and Australia, data protection laws restrict transferring personal information outside the jurisdiction. We take appropriate steps to ensure that your personal information receives an adequate level of protection (by putting in place appropriate safeguards, such as contractual clauses e.g. EU approved standard contractual clauses), or that we are able to rely on an appropriate derogation under applicable privacy and data protection laws. You have a right to request access to any safeguard which we use to transfer your personal information outside of the UK and the EEA.

Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information is disclosed.

You have a right to contact us at sales@penguinholiday.co.nz for more information about the safeguards we have put in place (including a copy of relevant contractual commitments).

What are your rights

We want you to feel reassured that you have control of the information you provide to us. Subject to certain exemptions, and depending on relevant data protection laws, including in some cases upon our legal basis for processing your information there are certain rights you have over your personal information. These include:

• You can ask us to update any inaccurate, incomplete or out-of-date information we hold about you

• You can ask us to provide you with a copy of the information we hold on you, or that we transfer that information to another service provider

• You may request that we stop processing or using your information

• You may request that we delete any / all information we hold about you

• You may withdraw consent that you have provided to us

Where possible we will comply with your request, however, there may be instances where we cannot fulfil your request, or there will be consequences if we were to fulfil your request. We will always communicate with you about any consequences before going forward, or give you written reasons for any refusal. Under certain data protection laws, including the EU/UK GDPR, you may also (subject to certain exceptions):

• withdraw consent to our use of your information for marketing purposes;

• object to the processing of your personal data, where we collect your personal data for our legitimate interest;

• request your personal information be transferred to yourself or a third party without hindrance in a commonly used format.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

We will only perform the activities outlined above to the extent that such activities will not compromise privacy, security or any other legal interests.

You may also wish to make a complaint about the way we have handled your personal information or other interference with your privacy rights.

You can exercise any of these rights at any time by contacting us (see the Contact Us section) or your relevant privacy or data protection authority.

Contact us

Data Protection Officer

If you would like to exercise your rights, as listed above, you can also do this by contacting sales@penguinholiday.co.nz. One of our team will contact you within a reasonable time frame after receiving your enquiry or request to verify who you are in order to locate any accounts or bookings you may have with us or ask any follow up questions to better understand your enquiry.

Please contact us at the details below:

• calling us on 64 274287566

• email us at sales@penguinholiday.co.nz

• by post to Penguin Holiday NZ Ltd, 41 Mahalo Avenue, Wiri, Auckland, 2104.

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We will inform you whether we will conduct an investigation and the estimated completion date for the investigation process. After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view. If you are unsatisfied by our final response, you may escalate your complaint to the relevant regulatory body.

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Complaint to the Data Protection Authority

If you have any concerns or complaints about how we are collecting or processing your personal information, you can complain to your local data protection authority. We would ask that you first contact us to seek to resolve the concern or complaint in the first instance.

If you are in the UK/EU, please follow this link to locate the data protection authority most relevant to you: https://edpb.europa.eu/about-edpb/board/members_en

If you are in New Zealand, you may contact the Office of the Privacy Commissioner, New Zealand at https://www.privacy.org.nz/your-rights/making-a-complaint/

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Data Retention

We store most of your personal information in digital systems managed either by us or trusted external providers. In some cases, information may also be held in secure paper files.

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected. However, in certain situations, we may keep your data for longer—for example, to comply with legal, regulatory, tax, or accounting obligations.

We may also retain your data to maintain a clear record of our interactions in case of complaints, disputes, or if we reasonably expect legal action involving your personal information.

Data Security

At Penguin Holiday NZ, protecting your personal data is a top priority. We use a combination of physical, digital, and administrative safeguards to secure your information from unauthorized access, loss, misuse, modification, or disclosure.

We have procedures in place to handle any actual or suspected data breaches and will notify you and relevant authorities when required by law.

While we take every reasonable precaution to secure your information, please note that the internet is not entirely secure. We encourage you to be cautious when sharing personal information online.

Third-Party Links and Features

Links to Other Websites
Our website may include links to external websites. These third-party sites may collect or share your data. We do not control them and are not responsible for their privacy practices. We recommend reviewing their privacy policies when visiting external websites.

Third-Party Widgets
Some of our services feature third-party widgets, such as social media buttons (e.g., Facebook "Like"). These may collect your IP address, track your activity on our site, and use cookies to function correctly. These features are either hosted by third parties or directly on our site, and your interactions are governed by the privacy policies of the companies providing them.

Cookies and Website Usage

Our website uses standard technologies like cookies and web server logs to enhance your experience. For more details on how cookies are used, please refer to our [Cookies Policy].

This Privacy Policy was last updated in June 2025.