We at Surgar.net, Inc. (“Surgar”) know that you care about how your personal information is used and shared, and we take your privacy seriously. By accessing or using the Services (including without limitation the mobile version of the Surgar.net website (the “Mobile Site”) and the Surgar.net mobile application(s) available via the Apple App Store and the Android Marketplace (collectively, the “Mobile Application”)), you acknowledge that you accept and consent to the practices and policies outlined in this Privacy Policy. Remember that your use of Surgar.net’s Services is at all times subject to the Terms of Service, which incorporates this Privacy Policy. Any terms we use here without defining them have the definitions given to them in the Terms of Service.

This Privacy Policy contains the following sections:

What Does This Privacy Policy Cover?
How is Children’s Personal Information Treated?
What Information Does Surgar.net Display or Collect?
What Does Surgar.net Use My Information For?
Will Surgar.net Share Any of the Personal Information or Children’s Personal Information it Receives?
Is Information About Me Secure?
Third Party Links
What Choices Do I Have Regarding Information?
Notice for California Residents
Notice for Nevada Residents
What if I’m in a Different Country?
Will Surgar.net Ever Change this Privacy Policy?
This Privacy Policy explains how Surgar.net collects and uses information from its users, including our treatment of personally identifiable information. This policy does not apply to websites or the practices of companies that Surgar.net does not own or control, or to individuals that Surgar.net does not employ or manage, such as the third party links on the Services and third parties who publish their content via the Services.


If you are not of legal age to form a binding contract (in many jurisdictions, this age is 18), you may only use the Services and disclose information to us with your parent’s or guardian’s consent. Review this Privacy Policy with your parent or guardian and make sure you understand it, and do the same with the privacy policies of all websites you visit or mobile applications you use.

We only collect personal information through the Services from a child we know is under the age of 13 (or under the age of 16 for a child in the European Union) (each a “child”) when we have parental consent or when a student’s school, district, and/or teacher has agreed (via the terms described in more detail in the Terms of Service) to obtain parental consent for that child to use the Services and disclose personal information to us, for the use and benefit of the learning environment. If you are a child, please do not send any personal information about yourself to us if your parent has not provided consent or your school, district, and/or teacher has not obtained this prior consent from your parent or guardian, and please do not send any personal information other than what we request from you in connection with the Services. If we learn we have collected personal information from a child without appropriate consent as outlined herein, we will delete that information as quickly as possible. If you believe that a child may have provided us personal information in violation of this paragraph, please contact us at [email protected]

When we use the term “Personal Information” in this Privacy Policy, we are referring to personally identifiable information of individual, non-student registrants of the Services. References to “Children’s Personal Information” only apply to personally identifiable information of users who have registered for the Services as minor students (i.e., students under the age of 18). General references to “information” apply to all users.

If you are a student registrant and your parent or guardian has signed up for the Services with an Access Code provided by your teacher, you understand that your parent or guardian, teacher, or school administrator can view all information within or associated with your Services account, including, without limitation, messages between you and your teacher and grades you received on assignments.


Information You Provide to Us
We receive and store any information you knowingly enter on the Services, whether via computer, mobile phone, other wireless device, or that you provide to us in any other way. This information may include, without limitation, Personal Information such as your name, user name, email address, phone number, profile picture, school affiliation and location, billing and payment information (as it relates to purchases via Surgar.net Spotlight), and any other information necessary for us to provide our Services. If you are a student registrant, the only Children’s Personal Information we require is your name and user name; through the functionality of the Services, you may also be permitted to input a profile picture and an email address or phone number if you choose to provide that information.You can log in to our site using third-party sign-in services such as Office 365 or Google. These services authenticate your identity and provide you with the option to share certain personal information with us, including your name and email address, to pre-populate our account sign-up form. If you choose to enable a third party to share your third-party account credentials with Surgar.net, we may obtain additional information about you via that mechanism.If you use our referral service to tell another teacher or a parent about our Services, we may ask you for that person’s name, email address, and/or telephone number so that we can send that referral. Conversely, if someone provides us with information about you as part of the referral process, we may obtain that information from that other Surgar.net user. Individuals who want Surgar.net to delete their information can contact Surgar.net at [email protected] to request that we remove your information from our database.With your permission and consent, Surgar.net may access the contact list available on your mobile device or in your email accounts to allow you to connect to your contacts on Surgar.net and to invite them to join Surgar.net. When you invite others to join Surgar.net by using our referral page, we may send text messages or emails on your behalf to that person. Please understand that we do not use your contact list information for any purpose other than to send invitations or messages on your behalf and with your explicit consent.
Information Collected Automatically
We receive and store certain types of usage information whenever you interact with the Services. For example, Surgar.net automatically receives and records information on our server logs from your browser, including your IP address, Surgar.net cookie information, and the page(s) you requested. We also record the details of your activity on the Services, and the number and frequency of visitors to our site and its components.When you download our Mobile Application, we automatically collect information on the type of device, name and version of the operating system, name and version of the application, whether the currently logged-in user is a teacher, student, or other user type, the numerical mobile device user ID, as well as actions performed by the user in accessing the Mobile Application (“Mobile Usage Information,” which is considered part of “usage information” as described above). We do not, however, ask you for, access, or track any geographic, location-based information from your mobile device (i.e., any information regarding where your mobile device is located on the globe at a particular time) at any time while downloading or using our Mobile Applications. For clarity, that does not prevent us from asking you what school you are affiliated with.We also use third-party mobile analytics software to allow us to better understand the functionality of our Mobile Application and Mobile Site on your phone. This software may record information such as how often you use the Mobile Application, the events that occur within the Mobile Application, aggregated usage information, performance data, and where the application was downloaded from; this information is considered Mobile Usage Information.Cookies are alphanumeric identifiers that are transferred to your computer or mobile device to enable systems to recognize a computer or device and specify how and when pages in a site are visited and by how many people. Surgar.net cookies do not collect Personal Information or Children’s Personal Information, and we do not combine the general information collected through these cookies with other Personal Information or Children’s Personal Information to tell us who you are or what your user name or email address is. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave Surgar.net cookies activated, however, because you may not be able to log in or use many of the Services’ most attractive features without cookies enabled. Our partners, affiliates, and service providers, including our advertising partners, may also transmit cookies to your browser or device when, for example, you click on an advertisement that appears on the Services. The use of cookies by third parties is not covered by this Privacy Policy, and we do not have access or control over such cookies.The Services may also contain electronic images known as web beacons (sometimes called single-pixel gifs), which are used along with cookies to compile aggregated statistics to analyze how the Services are used.


When you use the Services, you may set up your personal profile, form relationships, send messages, perform searches and queries, and transmit information through various channels, depending on the category of user (“User Category”) you are registered as, and as permitted by the functionality of the Services. The information we gather from users enables us to provide, personalize and improve our services, and allows users to set up a user account and profile through the Services.
Personal Information
The Personal Information you provide also is used for such purposes as responding to your requests for certain information and services, customizing your experience, and communicating with you about the Services.
Children’s Personal Information
We use the Children’s Personal Information for creating your individual account (which will identify you within your Limited Access Groups as applicable), customizing your experience, and for sending you notifications via the Services from your teacher, school, district, fellow Limited Access Group members, and from Surgar.net (regarding your use of the Services) (“Notifications”). Please note that your parent or guardian, as well as an administrator from your school and/or district, can view all activity and content associated with your student account, including your Children’s Personal Information.
Your email address
If you provide us your email address, we may send you email communications. Web beacons may also be used in some of our emails to let us know which emails (and which links within those emails) have been opened by recipients. This allows us to gauge the effectiveness of our customer communications. If you are a student, we will only use your email address to send you Notifications. If you no longer wish to receive emails from Surgar.net, please click the unsubscribe link that is included in the footer of our emails, update your email preferences, or contact us at [email protected] note that if you do not want to receive legal notices from us via email, such as this Privacy Policy, those legal notices will still govern your use of the Services, and you are responsible for visiting this Privacy Policy from time to time to review any changes.
Your friend’s email address or telephone number
If you provide us with another teacher’s or a parent’s name, email address, and/or telephone number, we will automatically send that individual an email inviting him or her to visit the Services. We store this information for the sole purpose of sending this email (and, if applicable, subsequent “reminder” emails) and tracking the success of our referral program. The referred person may contact us at [email protected] request that we remove this information from our database.
Usage Information
Surgar.net uses this type of aggregate data to enable us to figure out how often users use parts of the Services, so that we can make the Services appealing and relevant to as many users as possible, and customize and improve those Services. As part of our use of information, we may provide aggregate information to our partners (in a non-personally-identifiable format) about how our users use our site. We share this type of statistical data so that our partners also understand how often people use our partners’ services and the Services to help provide you with an optimal online experience. We may link usage information to Personal Information and Children’s Personal Information that we collect through the Services, but we will only use this linked information internally (for example, to customize your experience), and will not disclose it in linked format to third parties. Additionally, certain usage-related information may be viewable in your user profile that may be displayed to other users, depending on your User Category; for example, a “badge” may displayed in your profile indicating that you have added content to your user “library,” or that you have logged into the Services more than a certain number of times.
Mobile Usage Information
This information is used to determine device capabilities and usage trends, which allows us to better understand which devices we should support and what features are most frequently used. We do not link this information we obtain from the analytics software to any personally-identifying information that you submit within the mobile application.
Surgar.net does not provide any personally-identifying information to advertisers or our advertising partners. Nor do we sell or rent your personal information to anyone for any purposes, including advertising or marketing. In order for us to continue to be able to provide the Surgar.net Services to our users for free, Surgar.net and our third-party advertising partners may serve advertisements to you when you visit our website. To serve those advertisements, our third-party advertising partners, such as Google AdX, may utilize cookies. Because the privacy of our users is so important to Surgar.net, we have implemented a number of policies and technical measures to make sure that this advertising is done appropriately. Among other things, Surgar.net is not creating behavioral profiles of users for advertising or marketing purposes, and we are not sharing personally-identifiable information, such as a user’s name, email address, or phone number, with third parties for advertising purposes.
Push Notifications
If you use the Mobile Application, we will send push notifications to your mobile device in order to make you aware of certain activities that may occur within your account, such as when someone has entered a new post, when you have new notifications, or when grades have been posted. You may opt-out of receiving these types of communications by turning them off at the device level or emailing us at [email protected]


Personal Information and Children’s Personal Information about our users is an integral part of our business. We neither rent nor sell your Personal Information or Children’s Personal Information; we may share your Personal Information and Children’s Personal Information in personally identifiable form only as described below. Again, please note that references to “Personal Information” only apply to personal information of individuals who are not students.

Businesses We Do Not Control
In certain situations, businesses or third party websites we’re affiliated with may offer or sell items or provide services to you through the Services (either alone or jointly with us), including Third-Party Content and advertisements for third-party services and goods. We may, for example, work jointly with other businesses to offer or sell products or provide services, or we may work with third-party websites to enhance your online experience. These transactions or services may or may not be commercial in nature. We have designed the Services to enable you to recognize when such a business is associated with a transaction or service. We will share your Personal Information or Children’s Personal Information with such a business only to the extent that it is related to such transaction or service that you have initiated; for example, we may share your school affiliation and location with a Publisher of a Spotlight Resource to allow that Publisher to determine its tax liability in connection with such transaction. Such services may include the ability for you to automatically transmit information you input on the Services to your profile or account on a third-party website, or automatically to transmit information you input on a third-party website to your Services profile. We have no control over the policies and practices of third-party websites or companies as to privacy or anything else, so please review all third-party websites’ policies before disclosing any Personal Information or Children’s Personal Information or other content on the Services or on any third-party website (via the automatic transmissions discussed above or otherwise). Surgar.net does prohibit Publishers from collecting or using any information beyond what Surgar.net itself collects and uses pursuant to its Privacy Policy, but that does not mean that we are responsible for reviewing or verifying the accuracy of any Publisher’s data collection or use policies.
Service Providers
We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Examples include sending email, analyzing data, processing payment, and providing user services. Unless we tell you differently, Surgar.net’s agents do not have any right to use Personal Information or Children’s Personal Information we share with them beyond what is necessary to assist us.
User Profiles
If your User Category allows it, you may choose to populate your user profile on the Services with Personal Information or Children’s Personal Information, including, without limitation, your name, photograph, and school affiliation. This user profile information will be displayed to other users to facilitate user interaction within the Services or facilitate interaction with Surgar.net. If you are a student, the only users who may view your profile are those who belong to your Limited Access Group(s). However, please keep in mind that information (whether Personal Information or Children’s Personal Information or not) or content that you voluntarily disclose online (in “communities,” your Limited Access Groups, to your connections, in comments to our blog, etc.) becomes available to other users and can be collected and used by others, in accordance with the privacy settings you select in your account preferences, or in accordance with the User Category to which you belong. Any images, captions or other content that you submit to the Services in a manner any other user can view may be redistributed through the Internet and other media channels. For example, if you are a student, the content you contribute in your Limited Access Group(s) will be displayed to other members of that Limited Access Group; we cannot, however, control what members of your Limited Access Group will do with such content after you have disclosed it. Your name may be displayed to other users when you upload images or videos or send messages through the Services and other users can contact you through messages and comments.
Communication About the Services or in Response to User Requests
As part of the Services, you may receive from Surgar.net (depending on your User Category) email or other types of communication relating to your use of the Services or your user profile. You acknowledge and agree that by posting information on the Services or otherwise using the Services, Surgar.net and its agents may send you email, contact you, or engage in other communications that they determine relate to your profile or use of the Services. If you disclose your email address to Surgar.net, depending on your User Category, we may use it to send updates, a newsletter, or other news regarding the Services, or simply to send Notifications. If you are a student, Surgar.net only uses your email address or phone number to send you Notifications.
Business Transfers
If Surgar.net, or some or all of its assets, were acquired or otherwise transferred, or in the unlikely event that Surgar.net goes out of business or enters bankruptcy, user information may be transferred to or acquired by a third party; any such third party will be subject to the same commitments for previously collected Personal Information or Children’s Personal Information as Surgar.net is under this Privacy Policy.
Protection of Surgar.net and Others
We may release Personal Information or Children’s Personal Information when we believe in good faith that release is necessary to comply with the law (such as to comply with a subpoena); enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Surgar.net, our employees, our users, or others. We will try to give you notice if we release information for these reasons, but please understand that we reserve the right not to, as it may not be practical, legal, or safe to do so.


Your Surgar.net account Personal Information or Children’s Personal Information is protected by a password for your privacy and security, as well as by numerous other technical, administrative, and physical security mechanisms. We also use coding practices that take steps to prevent attacks on our Services from web browsers and malicious scripts, by processing all actions through several permission verifications checks.

You may help protect against unauthorized access to your account and Personal Information or Children’s Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.

When you enter sensitive information (such as a credit card number) in our Credit purchasing process, we encrypt the transmission of that information using secure socket layer technology (SSL).

Surgar.net endeavors to keep your information private; however, we cannot guarantee security. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information. For additional information about the security measures we use in connection with the Services, please contact us at [email protected]


The Services contain links to other sites, including YouTube. We are not responsible for the privacy policies and/or practices on other sites, but you should read all third parties’ privacy policies and terms of service to ensure you understand them (for example, please read YouTube’s terms of service and Google’s privacy policy). This Privacy Policy only governs information collected by Surgar.net on the Services.


This section outlines the choices you have regarding your information and Children’s Personal Information. You can always opt not to disclose information, even though it may be needed to take advantage of certain of our features; you can do so via your User Profile page or your Account Settings page. You are able to update or delete certain information, as described in this section.

In addition to the information in this section, you may also have rights if you are the resident of certain jurisdictions, as set forth below.

Access to Personal Information:

Surgar.net supports an individual’s right to access their Personal Information. We allow you to access the following information about you for the purpose of viewing, and in certain situations, updating, correcting, or deleting that information. This list may change as the Services change. To obtain this information, you can go to your User Profile page or to your Account Settings page; you can also submit a written request to [email protected]

You may currently access the following information, if your User Category allows you to input any of the following:

information in your user profile
user connections list, your groups (including Limited Access Groups), and communities
user preferences
content in your account
Deletion of Personal Information or Your Account

To request removal of your Personal Information from our public forums, contact us at [email protected] In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to do so and why.

You may request deletion of your Surgar.net account by following the directions here. Please note that some unrevised information may remain in our records after revision of such information or deletion of your account, or in cached and archived pages. Some information may remain viewable elsewhere to the extent that it was copied or stored by other users. We may use any aggregated data derived from or incorporating your Personal Information after you delete your information, but not in a manner that would identify you personally.

Choices about Children’s Personal Information

If you would like to request that Children’s Personal Information regarding your child be updated or deleted, or if you’d like to refuse further contact of your child (or, if you are a teacher, a child that is in your class) by the Services, please contact us at [email protected] A minor student’s participation in our Services, and the ability of a minor student to access the Services, will not be conditioned on that student providing more Children’s Personal Information than is reasonably necessary for that participation or access. We will respond to a request made pursuant to this section within thirty days of our receipt of such request.


We will retain your Personal Information or Children’s Personal Information for as long as your account is active or as long as needed to provide you the Services; we also may retain and use your information as we deem it necessary to comply with our legal obligations, resolve disputes, and to enforce our agreements.


If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). This information and the rights discussed below do not apply to information collected from about our employees, former employees, candidates, contractors, service providers, or business contacts of Surgar.net.

Categories of personal information we collect, use and disclose. Throughout this Policy, we discuss in detail the specific pieces of information we collect from and about users and discuss how we use and share such information. The following are the “categories” of personal information under the CCPA that we collect and that we may, as discussed throughout this Policy, use and disclose for our business purposes.

We may collect, use, and disclose for business purposes, the following categories of information about you or your use of the Products: Identifiers (such as name, address, email address); device identifiers; internet or other network or device activity (such as browsing history or app usage); location data; physical characteristics or description (e.g., if you voluntarily submit a photo); educational data; and other information that identifies or can be reasonably associated with you.

How we use these categories of personal information. We use the categories of personal information we collect from and about you consistent with the various business purposes we discuss throughout this Policy. Please see “WHAT DOES Surgar.net USE MY INFORMATION FOR?” above for more information.

Sale of personal information. The CCPA sets forth certain obligations for businesses that “sell” personal information. We do not sell personal information and have not engaged in such activity in the past twelve months. We do share certain personal information with other entities as outlined in this Policy. See “WILL Surgar.net SHARE ANY OF THE PERSONAL INFORMATION OR CHILDREN’S PERSONAL INFORMATION IT RECEIVES?” above.

California Privacy Rights

CCPA Rights. California residents can make certain requests about their personal information under the CCPA. Specifically, if you are a California resident, you may request that we:

provide you with information about: the categories of personal information we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we share personal information. Such information is also set forth in this Policy.
provide access to and/or a copy of certain information we hold about you;
delete certain information we have about you; and/or
provide you with information about the financial incentives that we offer to you, if any.
California residents can also designate an authorized agent to make such requests on their behalf.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Please note that certain information may be exempt from such requests under California law. For example, we may need certain information for legal compliance, in order to provide the Services to you, or because we are acting at the direction of a school. We also will take reasonable steps to verify your identity before responding to a request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at [email protected] or visit here.

Shine the Light Disclosure. Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes.


Under Nevada law, certain Nevada consumers may opt out of the sale of their personal information. We do not engage in such activity. If you have questions you may contact us at [email protected]

When you use the Services, you are consenting to have your data transferred to and processed in the United States. Please understand that Surgar.net is subject to the investigatory and enforcement powers of the Federal Trade Commission of the United States. All of Surgar.net’s servers are currently in the United States, and we aren’t able to process your information within the borders of any other country. Given this limitation, if your use of the Services or disclosure of certain information to Surgar.net would violate any law that is applicable to you, your right to use the Services and/or disclose such information is revoked, as it is wherever use of the Services is prohibited by law (as described in the Terms of Service).


Surgar.net complies with the E.U.-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Surgar.net has certified that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern with respect to residents of the E.U and Switzerland. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

As required under the Privacy Shield Principles, when we receive information under the Privacy Shield and then transfer it to a third-party acting as a controller or as an agent on our behalf, then we remain responsible for the processing of such personal information and subsequently transferred to a third party acting as an agent if the agent processes such personal information in a manner inconsistent with the Privacy Shield, unless we prove that we are not responsible for the event giving rise to the damage. In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Surgar.net commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact Surgar.net at [email protected]

Surgar.net has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Please understand that we may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. It is not our intent to pass on any such personal information to public authorities, but in the identified circumstances, we may be required to do so.

Legal Grounds for Using (Processing) Your Information

For users in the EEA, United Kingdom, and Switzerland, our legal basis for collecting and using the information described above will depend on the information concerned and the context in which we collect it. We collect information from you:

where we need it to perform our contract with you (i.e. our Terms of Service),
where the processing is in our legitimate interests (i.e. personalizing our services and marketing), provided that these aren’t overridden by your interests or rights, or
if we otherwise have your consent.
If you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact us using the contact details provided under the “Contact Us” section below.

Choices about Your Information

You may have certain legal rights to access certain information we hold about them and to request its deletion. For example, your local laws may permit you to request that we:

provide access to and/or a copy of certain information we have about you;
prevent the processing of your information for direct-marketing purposes;
update information which is out of date or incorrect;
delete certain information which we have about you;
restrict the way that we process and disclose certain of your information;
transfer your information to a third party provider of services; and
revoke your consent for the processing of your information.
We will consider all requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Us” section below at any time.


We may make changes to this Privacy Policy from time to time for any reason. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected. If we make material changes in the way we use Personal Information or Children’s Personal Information, we will endeavor to notify you via email or by posting an announcement on the Services with two (2) weeks prior notice before the change becomes effective. Users are bound by any changes to the Privacy Policy when he or she continues to use the Services after such time. You understand that it may not be possible in certain situations to provide advance notice of other changes to the Privacy Policy or to the Terms of Service (for example, where a change to the Privacy Policy or Terms is necessary to comply with legal requirements).