Terms and Conditions of Service
And Privacy Policy of EPOCH

SECTION B: PRIVACY POLICY

Terms and Conditions of Service

And Privacy Policy of EPOCH

Effective Date: 2 October 2026

Welcome to EPOCH. This document governs access to and use of the website, its content, and the services offered by EPOCH. Use of the site constitutes full acceptance of the following Terms and Conditions. The processing of your personal data is described in Section B (Privacy Policy). Consents relating to your data are specific, optional, and may be withdrawn at any time, as explained below.

SECTION A: TERMS AND CONDITIONS OF SERVICE

1. Definitions

Service: the website attributable to "EPOCH", its editorial content, its newsletter, and any product or service, current or future, offered through it.

Owner: the Service is offered and managed by Michele Bottelli, based at Via Giacomo Leopardi 4, 24127 Bergamo (BG), Italy, VAT number 04802370165, email: info@epochwine.it.

User: any natural or legal person who accesses, browses, or uses the Service.

2. Scope of the Service

EPOCH is an editorial project whose concept pairs a specific wine vintage with the events, culture, and news of that same year. The Service has informational, cultural, and commercial purposes, including the sale of related editorial products and the offering of dedicated editions to professionals in the wine sector.

3. Acceptance of the Terms

Accessing the site and browsing its content constitute acceptance of these Terms and Conditions with respect to the use of the site. Subscribing to the newsletter, submitting a request through the contact forms, and purchasing a product are governed, in addition to these Terms, by their respective specific conditions and by the Privacy Policy. Consents to the processing of data for marketing purposes are given separately and may be withdrawn at any time, without affecting the lawfulness of processing carried out before withdrawal. A User who does not accept these Terms must refrain from using the Service.

4. Eligibility

Use of the Service is permitted to Users who have the legal capacity to enter into binding contracts under applicable law. Purchases through the Service require the User to be of legal age in their country of residence. The Service is not directed at minors.

5. Acceptable Use

The User agrees to use the Service lawfully and in accordance with these Terms. The following are prohibited: automated extraction of content (scraping, crawling, or data mining) without prior written authorization; reproduction, resale, or systematic redistribution of the content; any conduct that may compromise the security, integrity, or availability of the Service; unauthorized access to systems or areas of the site; and use of the Service for unlawful, defamatory, or fraudulent purposes. The Owner reserves the right to suspend or block access in the event of a breach.

6. Content of the Service and Limitation of Liability

6.1. Nature of the Content. EPOCH's content falls into two main categories:

Historical and factual content: narratives of historical, political, social, sporting, and news events, based on public domain sources, historical archives, and journalistic material.

Oenological content (informational and editorial): information on territories, grape varieties, appellations, and producers, together with analyses and descriptions that express the editorial sensibility of the Owner and their collaborators. EPOCH tells the story of each wine in relation to its own historical potential, and assigns no scores, ratings, or comparative rankings among producers.

6.2. Accuracy, Errors, and Omissions. The Owner strives to ensure the highest possible accuracy for historical and factual content, relying on verified sources. Given the breadth of the subject matter, the Owner offers no absolute guarantee as to accuracy, completeness, or the absence of errors and omissions. Information is provided "as is". Any User who identifies an error is invited to report it to info@epochwine.it. The Owner will assess the report and reserves the right, at their sole discretion, to make corrections.

6.3. Disinformation and Editorial Stances. EPOCH is a cultural project and not a political news outlet. The Owner disclaims all liability for interpretations of the content that may be construed as disinformation or as political stances. The narration of historical events serves solely to contextualize the relevant wine vintage and promotes no ideology. Any perception of bias is to be considered unintentional and incidental.

6.4. Right to Criticize. The analyses and editorial descriptions of wines and territories are the legitimate exercise of the right to criticize and to freely express opinion (Article 21 of the Italian Constitution). They represent subjective opinions, based on the experience and sensibility of the author, make no claim to absolute truth, and are in no way intended to harm the image or reputation of the producers mentioned.

7. Intellectual Property and Copyright

7.1. EPOCH Content. All original texts, analyses, graphics, the logo, the design, and the structure of the Service are the exclusive intellectual property of Michele Bottelli, protected by Italian and international copyright law. Any unauthorized reproduction, distribution, or use is prohibited.

7.2. Third-Party Trademarks. The names of wineries, wines, appellations (DOC, DOCG, IGT), and other registered trademarks belonging to third parties are used within the Service solely for descriptive and identifying purposes, in compliance with Article 21 of the Italian Industrial Property Code. Such use implies no affiliation with, or endorsement by, the respective owners.

7.3. Third-Party Material. Any use of third-party copyrighted material (for example, historical photographs or quotations) is made in compliance with applicable law, and only where the material: belongs to the public domain; is covered by a valid licence; or falls within the limits of the right of quotation or reporting (Article 70, Italian Law 633/1941) for purposes of criticism, discussion, or teaching. Any rights holder who believes their material has been used improperly is invited to contact the Owner at info@epochwine.it for review and prompt removal where appropriate.

8. Sale of Products

The Service allows the purchase of EPOCH editorial products. Sales are governed by this Section 8, which sets out prices, payment methods, shipping, withdrawal, and warranties, together with the product information shown on the relevant product page at the time of purchase.

8.1. Prices and Availability. Prices are shown on the product page and include or exclude taxes and shipping costs as indicated at checkout. Product availability is limited, particularly for numbered editions, and is confirmed at the time the order is accepted. No VAT is charged on sales made through the Service, and no VAT is added at any stage of the order. Invoices are issued accordingly, bearing the notation required by Italian law.

The Owner reserves the right to refuse or cancel any order, including after an order confirmation has been sent, in the event of unavailability of the product, a manifest error in the price or description displayed, or suspected fraudulent or unlawful use of the Service. In such cases, any amount already paid by the User will be refunded in full, and the Owner's liability is limited to that refund.

8.2. Payments. Payments are processed by independent third-party payment providers (currently Stripe and PayPal), which act as payment processors. The Owner is the merchant of record for all sales made through the Service and is solely responsible for the sale, including applicable taxes and compliance obligations. Payment disputes, chargebacks, and refunds initiated through a payment provider are handled in accordance with that provider's own terms and procedures, which are outside the Owner's control. Payment instrument data is processed and stored exclusively by the relevant payment provider and is never accessed or stored by the Owner.

8.3. Right of Withdrawal (Consumers). Consumers within the European Union have the right to withdraw from the purchase within 14 days of receiving the goods, in accordance with the Italian Consumer Code (Legislative Decree 206/2005). To exercise the right of withdrawal, the consumer must inform the Owner of the decision to withdraw by an unequivocal statement (for example, a letter sent by post or an email), using the model withdrawal form below or any other clear statement. You will bear the direct cost of returning the goods, except in the case of goods that are faulty or not as described.

The Owner may withhold reimbursement until the goods have been received back, or until the consumer has supplied evidence of having sent back the goods, whichever is earlier. The consumer is liable for any diminished value of the goods resulting from handling other than what is necessary to establish the nature, characteristics, and functioning of the goods; any such diminished value will be deducted from the refund.

Model Withdrawal Form

(Complete and return this form only if you wish to withdraw from the contract)

To: Michele Bottelli, Via Giacomo Leopardi 4, 24127 Bergamo (BG), Italy. Email: info@epochwine.it

I/We hereby give notice that I/We withdraw from my/our contract of sale of the following goods:

Ordered on / received on:

Name of consumer(s):

Address of consumer(s):

Signature of consumer(s) (only if this form is notified on paper):

Date:

8.4. Exclusion of the Right of Withdrawal for Personalized Products. In accordance with Article 59 of the Italian Consumer Code and Article 16 of Directive 2011/83/EU, the right of withdrawal is excluded for goods made to the consumer's specifications or clearly personalized. This applies to EPOCH editions bearing the customer's name (engraved, foiled, or otherwise personalized) and to any edition produced to individual specifications. This exclusion is brought to the consumer's attention before the order is placed.

The sole fact that an edition is numbered as part of a limited print run does not, by itself, constitute personalization for the purposes of this article: the right of withdrawal remains excluded only for elements produced to the consumer's individual specifications (for example an engraved or foiled name, or a personalized binding), not for numbering alone.

For personalized products, the right of withdrawal described in Section 8.3 does not apply, and the Owner is under no obligation to accept their return. The Owner may nonetheless, at its sole discretion and on a case by case basis, offer the consumer a store credit to be used on the Service in lieu of a refund, conditional on the product being returned in good condition and on payment, by the consumer, of the return shipping costs. This possibility is a commercial courtesy, not a right the consumer may invoke, and does not constitute an exercise of the right of withdrawal under Section 8.3.

The exclusion of the right of withdrawal for personalized products does not affect the legal warranty of conformity described in Section 8.5, which remains fully applicable in the event of a defect or non-conformity, regardless of the degree of personalization.

8.5. Legal Warranty. Consumers benefit from the legal warranty of conformity provided by applicable law.

8.6. Customs Duties and Import Taxes. For deliveries outside the European Union, the price shown does not include import duties, taxes, or customs clearance fees applicable in the destination country. These charges, where due, are the sole responsibility of the recipient and are collected by the customs authority or courier at the time of import. The Owner has no control over the amount of such charges and cannot predict them in advance. By placing an order for delivery outside the European Union, the User is considered the importer of record and agrees to comply with all import regulations of the destination country.

8.7. Force Majeure. The Owner shall not be liable for any delay or failure to perform any obligation under these Terms (other than payment obligations) caused by circumstances beyond its reasonable control, including but not limited to natural disasters, acts of government, war, civil unrest, strikes, carrier disruptions, or supplier failures. In such cases, the affected obligation is suspended for the duration of the event, and estimated delivery dates become non-binding.

8.8. Risk of Loss and Transport Damage Claims. For consumer purchases, risk of loss or damage to the goods passes to the consumer upon physical delivery to the consumer or to a third party designated by the consumer, other than the carrier, in accordance with applicable consumer protection law. For orders placed by a business or professional (B2B), risk of loss or damage passes upon handover of the goods to the first carrier.

We recommend photographing the packaging and the product at the time of delivery if you notice any damage or anomaly, as this helps us process your request more quickly. This recommendation does not affect your statutory rights under applicable consumer protection law. For orders placed by a business or professional (B2B), any claim for transport damage or shortage must be submitted to the Owner within 48 hours of delivery, together with photographic evidence of the packaging and of the product as received. Claims submitted after this period or without supporting evidence may be declined.

8.9. Business and Professional Purchases (B2B). Purchases made by a business or by a professional acting in the course of their trade, business, craft, or profession are not consumer purchases, and the protections reserved to consumers under this Section 8 do not apply to them. In particular:

(a) The right of withdrawal set out in Section 8.3 is reserved to consumers and does not apply to business orders. Once confirmed, a business order is binding.

(b) The consumer legal warranty set out in Section 8.5 does not apply. Defects must be reported to the Owner within 8 days of their discovery, and the warranty period is 1 year from delivery, in accordance with Article 1495 of the Italian Civil Code.

(c) These Terms are governed by Italian law, and the United Nations Convention on Contracts for the International Sale of Goods (Vienna, 1980) is expressly excluded.

8.10. Custom Orders for Business Clients. This Section 8.10 applies, in addition to Section 8.9, to orders placed by a business or professional client for products made to custom specifications, including personalized branding, engraving, or bespoke editions such as THE MONOLITH.

(a) Design Approval. Production begins only after the client has approved, in writing (including by email), a proof or mock-up of the requested customization. Once approved, the order is final as to the approved specifications.

(b) Deposit. Where an order requires a deposit, the deposit is non-refundable if the client cancels the order after production has started, reflecting the cost of labor and materials already committed to goods made to that client's specifications.

(c) Retention of Title. Ownership of the goods remains with the Owner until the price has been paid in full, in accordance with Article 1523 of the Italian Civil Code. Risk of loss passes to the client upon delivery in accordance with Section 8.8, notwithstanding retention of title.

(d) Right to Withhold Delivery. Where payment is agreed in installments, the Owner is not required to deliver the goods, or to transfer any certificate of authenticity or provenance, until the full price has been received.

(e) Late Payment. Late payment on invoices issued to a business client is subject to the statutory interest and recovery costs provided for by Italian Legislative Decree No. 231/2002 on late payments in commercial transactions, without need for prior notice.

(f) Client-Supplied Marks. Where a business client requests that its own name, logo, or trademark be applied to a product, the client warrants that it holds the necessary rights to authorize such use and agrees to indemnify the Owner against any third-party claim arising from that use. The Owner acquires no rights in the client's marks beyond what is necessary to fulfill the order.

(g) Uncollected Goods. If a business client fails to accept delivery or to provide shipping instructions within 30 days of notice that the order is ready, the Owner may charge reasonable storage costs and, after a further 30 days' written notice, may dispose of or resell the goods, applying any proceeds first to sums owed by the client.

(h) Price Revision on Extended Production. For orders with a production time exceeding 90 days, the Owner may adjust the agreed price to reflect a material increase in the cost of materials, provided the client is notified before production continues. If the client does not accept the revised price, the client may cancel the order without penalty, except for the non-refundable portion of the deposit described in paragraph (b) to the extent already spent on the client's specifications.

9. Third-Party Links and Services

The Service may contain links to third-party websites or platforms (for example, crowdfunding platforms, social networks, or payment providers). The Owner exercises no control over such sites and assumes no liability for their content, availability, or privacy practices. Access to third-party sites is at the User's own risk and is governed by their respective terms.

10. Disclaimer of Warranties

The Service is provided "as is" and "as available". The Owner makes no warranty that the Service will be uninterrupted, error free, secure, or free of harmful components, nor that the content will meet the User's specific expectations. The Owner reserves the right to modify, suspend, or discontinue the Service, in whole or in part, at any time.

11. Limitation of Liability

To the fullest extent permitted by applicable law, the Owner shall not be liable for indirect, incidental, consequential, or punitive damages, nor for loss of profits, loss of data, or loss of opportunity, arising from the use of, or inability to use, the Service. Where liability cannot be excluded, it is limited to the amount actually paid by the User to the Owner for the product or service giving rise to the claim. Nothing in these Terms limits liability for wilful misconduct, gross negligence, or any liability that cannot be excluded under mandatory law, including the mandatory rights of consumers.

12. Indemnification

The User agrees to hold the Owner harmless from any claim, damage, liability, or expense (including reasonable legal fees) arising from a breach of these Terms by the User, from unlawful use of the Service, or from the infringement of third-party rights.

13. Changes to the Terms

The Owner reserves the right to amend these Terms at any time. Amendments take effect upon publication on this page, with an updated effective date. Continued use of the Service after publication constitutes acceptance of the amended Terms. For purchases already concluded, the Terms in force at the time of the order continue to apply.

14. Severability and Entire Agreement

Should any provision of these Terms be held invalid or unenforceable, the remaining provisions shall remain in full force and effect. These Terms, which include the Privacy Policy set out in Section B, together with the Cookie Policy where one is in force, constitute the entire agreement between the User and the Owner regarding the Service.

15. Governing Law, Jurisdiction, and Dispute Resolution

These Terms are governed by Italian law. For consumers, the mandatory jurisdiction of the court of their place of residence or domicile remains unaffected, as do the mandatory protections of the law of their country of habitual residence. For any other dispute, exclusive jurisdiction lies with the Court of Bergamo, Italy. Consumers may also seek resolution through the alternative dispute resolution bodies available under applicable law. Any complaint may first be addressed to the Owner at info@epochwine.it.

Where the User is a consumer resident in Australia, nothing in these Terms limits, excludes, or modifies any consumer guarantee, right, or remedy conferred on the User under the Australian Consumer Law (Schedule 2 to the Competition and Consumer Act 2010, Cth) that cannot lawfully be excluded, restricted, or modified by agreement.

SECTION B: PRIVACY POLICY

(pursuant to Articles 13 and 14 of Regulation (EU) 2016/679, GDPR)

16. Data Controller

The Data Controller is Michele Bottelli, based at Via Giacomo Leopardi 4, 24127 Bergamo (BG), Italy, VAT number 04802370165, email: info@epochwine.it.

17. Types of Data Processed

Navigation data: data whose transmission is implicit in the use of Internet communication protocols (for example, IP addresses and system logs).

Data provided voluntarily by the User:

Newsletter subscription: name and email address.

Professionals (B2B) contact form: name, company, email address, and the content of the message.

Purchases: personal details, shipping address, contact information, and tax data for invoicing. Payment instrument data is handled directly and exclusively by secure payment providers (for example, Stripe).

Cookies and tracking technologies: the site uses technical cookies, which are necessary for its operation and do not require consent. Every other cookie or tracking technology is activated only after the User has given consent through the consent management banner, and consent may be withdrawn at any time through the same banner. Depending on the tools in use at any given time, these may include:

Analytics and audience measurement, used to understand how the site is used in aggregate (for example, Google Analytics, Wix Analytics, or equivalent).

Behavioural analysis, heatmaps, and session recording, which may register pages viewed, clicks, scrolling, and mouse movement (for example, Microsoft Clarity, Hotjar, or equivalent). Where such tools are used, form fields and payment data are masked and are not recorded.

Advertising and conversion tracking pixels, including server-side event tracking, which share event data with the relevant advertising platform (for example, Meta Pixel and Conversions API, Google Ads and Google tag, TikTok Pixel, Pinterest Tag, LinkedIn Insight Tag, Microsoft Advertising, or equivalent).

Tag management tools used to deploy and govern the technologies above (for example, Google Tag Manager, or equivalent).

Server-side tagging infrastructure, through which event data may be collected on a server controlled by or on behalf of the Owner and then forwarded to the platforms listed above (for example, Stape.io, server-side Google Tag Manager containers, or equivalent). Server-side collection is subject to the same consent requirements as client-side collection, and is not used to circumvent the User's choices.

Affiliate and referral tracking, used to attribute a purchase to the partner or affiliate who referred it (for example, GoAffPro, or equivalent).

Full details of the cookies actually in use at any given time, with their purpose and duration, are set out in the dedicated Cookie Policy, accessible from the banner.

18. Purposes and Legal Bases of Processing

PurposeData processedLegal basis (GDPR)

A) Providing the content and services of the siteNavigation dataPerformance of a contract or pre-contractual measures (Art. 6.1.b)

B) Managing and responding to requests submitted through the contact forms, including B2B enquiriesName, company, email, messagePre-contractual measures and legitimate interest in replying (Art. 6.1.b and 6.1.f)

C) Sending the newsletter and promotional communications about EPOCHName, emailConsent (Art. 6.1.a)

D) Statistical analysis of traffic and site usageNavigation and usage dataConsent for non-technical cookies (Art. 6.1.a); legitimate interest for aggregated analysis (Art. 6.1.f)

E) Managing orders, shipping, and invoicingPersonal, contact, shipping, and tax dataPerformance of a contract (Art. 6.1.b)

F) Complying with legal, accounting, and tax obligationsInvoicing dataLegal obligation (Art. 6.1.c)

G) Establishing, exercising, or defending legal claimsData as necessaryLegitimate interest of the Controller (Art. 6.1.f)

H) Advanced marketing and profiling, including targeted advertisingContact and navigation dataSpecific and optional consent (Art. 6.1.a)

I) Public thanks on the Founding Members page (Section 18-bis)First name, initial of the surname, shipping city, Founder N° or Kickstarter label; on request, full surnameLegitimate interest (Art. 6.1.f); consent for the full surname (Art. 6.1.a)

18-bis. Founding Members Page

Anyone who has received a Founder N°, or who supported EPOCH on Kickstarter, appears on the public page epochwine.it/grazie, which thanks the first people who supported the project ("Founding Members"). The page shows only the first name, the initial of the surname, the city of the shipping address and the Founder N°, or the label "Founding Member · Kickstarter". Anyone who types their first and last name into the page's search finds their own entry. No other order details appear. The legal basis is the Owner's legitimate interest in publicly thanking its first customers and in making the Founder N° printed on their certificates verifiable, with data kept to a minimum (Art. 6.1.f). The page is public and visible to anyone. Anyone who does not wish to appear, or prefers to show their country only, may ask at any time, without giving a reason, by replying to their order confirmation email or writing to info@epochwine.it: the change is made within 7 days. Anyone who wishes to appear with their full surname may ask in the same way, and in that case the legal basis is their consent, which may be withdrawn at any time (Art. 6.1.a). "Founding Member" is a title of gratitude: it does not make anyone a partner or founder and confers no shares or rights in the Owner's business.

19. Disclosure of Data to Third Parties

The Owner does not sell personal data to third parties for their own marketing purposes without explicit and separate consent. For the operation of the Service, data may be disclosed to providers belonging to the following categories, including, by way of example, the providers listed below or equivalent providers within the same category.

Most of these providers act as data processors appointed by the Owner under Article 28 GDPR. Some of them, in particular advertising platforms and certain analytics and behavioural analysis providers, process the data also for their own purposes and therefore act as independent or joint controllers: in that case the processing they carry out is governed by their own terms and privacy policies, to which the User is referred, and the Owner's role is limited to collecting valid consent before any data is transmitted to them.

Hosting and site infrastructure: Wix, or equivalent.

Forms and contact management: Wix, or equivalent.

Email marketing and newsletter: email marketing platforms (for example, MailerLite, Brevo, Mailchimp, Wix), or equivalent.

Automation and integrations: for example, Make, Zapier, or equivalent.

E-commerce and payments: Stripe, PayPal, or equivalent.

Analytics, behavioural analysis, and tracking: Google Analytics, Wix Analytics, Microsoft Clarity, Hotjar, heatmap and session recording tools, tag management tools such as Google Tag Manager, or equivalent.

Server-side tagging infrastructure: Stape.io, server-side Google Tag Manager containers, or equivalent.

Advertising and conversion tracking: Meta Platforms (Facebook, Instagram), Google, TikTok, Pinterest, LinkedIn, Microsoft Advertising, or equivalent.

Affiliate and referral programs: affiliate tracking platforms (for example, GoAffPro), or equivalent.

Customer support and messaging: chat, helpdesk, and messaging tools, or equivalent.

Product reviews and feedback: review collection platforms, or equivalent.

Cookie consent management: a consent management platform, where one is in use.

Artificial intelligence service providers: used for content generation and support activities, exclusively on professional plans offering adequate protection safeguards and under which personal data is not used for model training.

Professionals and advisors: accountants, lawyers, and tax advisors.

Shipping and logistics companies: for the delivery of purchased products.

Public authorities: where required by law.

20. International Transfers (Outside the EU)

The use of some of the services listed above may involve the transfer of personal data to countries outside the European Union, in particular the United States. Such transfers are carried out in compliance with the GDPR, on the basis of an adequacy decision of the European Commission (including, where applicable, the EU-U.S. Data Privacy Framework) or of Standard Contractual Clauses (SCCs) providing appropriate safeguards.

21. Data Retention

Data is retained only for as long as necessary:

Newsletter (purpose C): until consent is withdrawn.

Contact form requests (purpose B): for the time needed to handle the request and, where a relationship begins, for its duration.

Contractual and invoicing data (purposes E, F): 10 years from the end of the contractual relationship, as required by Italian law.

Marketing and profiling (purpose H): a maximum of 24 months from the collection of consent, unless renewed.

Founding Members page (purpose I): for as long as the page exists, unless the User objects. The customer's requests (removal, changes, consent): 5 years. The register of Founder N°s, which certifies the number printed on the customer's certificate, is kept for the entire life of the EPOCH project, even if the customer does not appear on the page.

22. Rights of the Data Subject

The User has the right, at any time, to: access their personal data (Art. 15); obtain rectification (Art. 16); obtain erasure (Art. 17); obtain restriction of processing (Art. 18); receive their data in a portable format (Art. 20); object to processing based on legitimate interest, including the Founding Members page, and to processing for direct marketing purposes (Art. 21); withdraw consent at any time, without affecting the lawfulness of prior processing; and lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali, www.garanteprivacy.it) or with the supervisory authority of their country. These rights may be exercised by writing to info@epochwine.it.

23. Nature of Data Provision

Providing data for the newsletter (purpose C) and for marketing (purpose H) is optional and based on consent: withholding it only prevents the receipt of such communications. Providing data through the contact forms (purpose B) is necessary in order to receive a reply. Providing data for a purchase (purpose E) is necessary for the performance of the contract. Appearing on the Founding Members page (purpose I) is not required for a purchase: anyone who asks to be removed loses nothing.

24. Minors

The Service is not directed at minors. The Owner does not knowingly collect personal data from minors below the age of digital consent applicable in their country of residence, without the consent of a person holding parental responsibility. Should such data be collected inadvertently, it will be deleted upon notice sent to info@epochwine.it.

25. Automated Decision-Making

The Owner carries out no automated decision-making producing legal effects concerning the User. Profiling for advertising purposes takes place only on the basis of specific consent, as described under purpose H, and the User may object to it or withdraw consent at any time.

26. Security

The Owner adopts appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or disclosure, in accordance with Article 32 GDPR. Data transmission over the Internet cannot, however, be guaranteed to be entirely secure.

27. Changes to this Privacy Policy

The Owner may update this Privacy Policy. Amendments take effect upon publication on this page, with an updated effective date. Users are invited to consult this page periodically.