Privacy Policy

Data protection is of particular concern to ISEC Visatec GmbH. Our efforts to fulfil the requirements of the European General Data Protection Regulation (GDPR) and the new version of the German Federal Data Protection Act (Bundesdatenschutzgesetz) are primarily aimed at respecting your privacy and personal sphere.

For modern companies such as ISEC Visatec GmbH, the use of electronic data processing systems (EDP) is indispensable nowadays. It goes without saying that we take the utmost care to comply with legal regulations.

The use of the Internet pages of the ISEC Visatec GmbH is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. However, if a data subject wishes to make use of special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

We will never sell or rent your personal information to third parties for their marketing or other purposes. If you do not agree with the terms of the privacy policy, please do not send any personal data to us.

1. General / Definitions

This privacy policy is based on terms used in the GDPR and should be easy to read and understand for everyone. We would therefore like to explain various terms in advance:

a) Personal data: Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject / person concerned: Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
c) Processing: Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing: Restriction of processing is the marking of stored personal data with the aim of restricting its future processing.
e) Profiling: Profiling is any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
f) Pseudonymisation: Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Responsible person: The controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor: Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient: Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular enquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) Third party: Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
k) Consent: Consent is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Information on the Collection of Personal Data

(1) In the following, we provide information about the collection of personal data when using our website. Personal data is all data that can be related to you personally, e.g. name, address, email addresses, user behaviour, etc.

(2) The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is the:

ISEC VISATEC GMBH
Gewerbepark 7
DE-87477 Sulzberg

(3) Our data protection officer is:

Mr Sascha Weller, lawyer, IDR – Institut für Datenschutzrecht
Ziegelbräustrasse 7
DE-85049 Ingolstadt
Phone: +49 (0)841 - 885 167 15
E-mail: ra-weller@idr-datenschutz.de
Web: https://idr-datenschutz.de (external data protection officer)

(4) When you contact us by e-mail or via a contact form, the data you provide (your e-mail address, possibly your name and telephone number) will be automatically stored by us in order to answer your questions. Such personal data transmitted on a voluntary basis by a data subject to the data controller will be stored exclusively for the purposes of processing or contacting the data subject. We delete the data arising in this context after storage is no longer required, or restrict processing if there are statutory retention obligations.

(5) If we use contracted service providers for individual functions of our offer or would like to use your data for advertising purposes, we will inform you in detail below about the respective processes. We will also state the specified criteria for the storage period.

(6) As the controller, we have implemented numerous technical and organisational measures to ensure that the personal data processed via this website is protected as completely as possible. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

(7) As a responsible company, we do not use automated decision-making or profiling.

3. Your rights

You have the following rights vis-à-vis us with regard to your personal data:

Right to Information

Any person affected by the processing of personal data has the right, granted by the GDPR, to obtain information free of charge at any time from the controller about the personal data stored about him/her and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:

The purposes of processing
The categories of personal data that are processed
The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
The existence of a right to lodge a complaint with a supervisory authority
If the personal data is not collected from the data subject: All available information about the origin of the data
The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

The data subject also has a right to information as to whether personal data has been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

Right to Withdraw Consent Under Data Protection Law

Any person affected by the processing of personal data has the right to withdraw consent to the processing of personal data at any time.

If a data subject wishes to exercise this right to withdraw consent, he or she may, at any time and by any means, contact any employee of the controller.

Right to Rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

Right to Cancellation / Right to Be Forgotten

The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

The personal data are no longer necessary for the purposes for which they were collected or otherwise processed
The data subject withdraws consent on which the processing is based and there is no other legal ground for the processing
The data subject objects to the processing and there are no overriding legitimate grounds for the processing
The personal data have been processed unlawfully
The deletion of personal data is necessary to fulfil a legal obligation under Union or Member State law
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR

If a data subject wishes to exercise this right to erasure / right to be forgotten, he or she may contact an employee of the controller at any time.

If we have made the personal data public and we are obliged to erase it pursuant to Art. 17(1) GDPR, we shall take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation, to inform controllers which are processing the personal data that a data subject has requested the erasure by such controllers of any links to, or copy or replication of, that personal data. Our employees will take the necessary measures.

Right to Restriction of Processing

The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data
The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims
The data subject has objected to processing pursuant to Article 21(1) GDPR, pending the verification whether the legitimate grounds of the controller override those of the data subject

If a data subject wishes to exercise this right to restriction of processing, he or she may, at any time, contact any employee of the controller.

Right to Object to the Processing

Any person affected by the processing of personal data has the right granted by the GDPR to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) GDPR. This also applies to profiling based on these provisions.

In the event of an objection, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

If we process personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This also applies to profiling insofar as it is associated with such direct advertising.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may contact any employee directly. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

Right to Data Portability

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

The processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a), or on a contract pursuant to Article 6(1)(b)
The processing is carried out using automated procedures

In exercising their right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

If a data subject wishes to avail himself of this right to data portability, he or she may, at any time, contact any employee of the controller.

Automated Decision in Individual Cases Including Profiling

Any person affected by the processing of personal data has the right granted by the GDPR not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, provided that the decision:

Is not necessary for the conclusion or fulfilment of a contract between the data subject and the controller
Is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests
Is made with the express consent of the data subject

If the decision is necessary for entering into, or the performance of, a contract between the data subject and a controller, or if the decision is based on the data subject's explicit consent, we shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the controller.

Supervisory Authority

You also have the right to complain to a data protection supervisory authority about the processing of your personal data by us. The supervisory authority responsible for our company is:

Bayerisches Landesamt für Datenschutzaufsicht
Promenade 18
91522 Ansbach
Phone: +49 (0)981 / 180093-0
Fax: +49 (0)981 / 180093-800
E-mail: poststelle@lda.bayern.de
Web: https://www.lda.bayern.de

4. Collection of Personal Data When Visiting Our Website / Cookies

If you use our website for information purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure stability and security (legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR):

IP address
Date and time of the enquiry
Time zone difference to Greenwich Mean Time (GMT)
Internet service provider of the accessing system
Content of the request (specific page)
Access status/HTTP status code
Amount of data transferred in each case
Website from which the request comes (referrer)
Browser
Operating system and its interface
Language and version of the browser software

In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive assigned to the browser you use and through which certain information flows to the body that sets the cookie (here by us). Cookies cannot execute programmes or transfer viruses to your computer. They are used to make the website more user-friendly and effective overall.

Use of Cookies

A basic distinction is made between the following cookie types/functions:

Transient cookies: Automatically deleted when you close the browser. These include session cookies, which store a session ID to link multiple requests. Deleted when you log out or close the browser.
Persistent cookies: Automatically deleted after a specified period, which varies by cookie. You can delete them manually in your browser's security settings.
Necessary cookies: Essential for website operation.
Statistical, marketing, or personalisation cookies: Used to measure reach or store user interests/behavior (e.g., tracking). If used, we will inform you in our privacy policy or via consent banners.

You can configure your browser to refuse all or some cookies. Please note this may limit website functionality.

We use cookies to identify you during future visits if you have an account. Otherwise, you would have to log in each time.

Data processed via cookies is generally based on our legitimate interests (Art. 6 para. 1 lit. f GDPR), or necessary for fulfilling contractual obligations (Art. 6 para. 1 lit. b GDPR). If we ask for consent, the processing is based on that consent (Art. 6 para. 1 lit. a GDPR).

You can withdraw your consent or object to cookie-based processing ("opt-out") at any time:

Through your browser settings
Via the US opt-out site: aboutads.info/choices
Via the EU site: youronlinechoices.com
Or generally: optout.aboutads.info

5. Further Functions and Offers of Our Website

In addition to the purely informational use of our website, we offer various services that you can use if you are interested. You may need to provide additional personal data for these services, to which the same data processing principles apply.

We sometimes use external service providers who are carefully selected, instructed, and monitored by us.

Our hosting services include: infrastructure and platform services, computing capacity, storage and database services, security services, and technical maintenance. These are provided based on our legitimate interest in efficient and secure operations (Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR).

We may also share your data with third parties for promotions, competitions, contracts, or similar services conducted with partners. More information will be provided when data is collected or in the relevant offer description.

If our partners or service providers are located outside the European Economic Area (EEA), we will inform you of the implications in the offer description.

Trans-Atlantic Data Privacy Framework (TADPF)

Under the Trans-Atlantic Data Privacy Framework, the EU Commission has recognized the data protection level of certain U.S. companies. See the list of certified companies and further info at:

https://www.dataprivacyframework.gov/ (U.S. Department of Commerce)
EU Commission site (in German and other languages)

We will also inform you about the specific companies we use that are certified under TADPF.

6. Data protection for applications

The controller collects and processes the personal data of applicants for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits relevant application documents to the controller electronically, for example by email or via a contact form on the website. If the controller concludes an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment contract in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted, provided that no other legitimate interests of the controller prevent deletion. Other legitimate interest in this sense is, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).

The processing of applicant data is carried out to fulfil our (pre-)contractual obligations in the context of the application procedure within the meaning of Art. 6 para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO if the data processing becomes necessary for us, e.g. in the context of legal proceedings (in Germany, § 26 BDSG also applies).

7. Objection or revocation against the processing of your data

(1) If you have given your consent to the processing of your data, you can revoke this at any time and by any means of communication. Such a revocation affects the permissibility of the processing of your personal data after you have given it to us.

(2) Insofar as we base the processing of your personal data on the balancing of interests, you can object to the processing. This is the case if, in particular, the processing is not necessary for the fulfilment of a contract with you, which is described by us in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the situation and will either discontinue or adapt the data processing or show you our compelling reasons worthy of protection on the basis of which we will continue the processing.

(3) Of course, you can object to the processing of your personal data for advertising and data analysis purposes at any time. You can contact us about your objection to advertising at the address given under point 2 (2).

8. Legal or contractual regulations for the provision of personal data/necessity for the conclusion of a contract/consequences of non-provision/deletion

We would like to inform you that the provision of personal data is partly required by law. However, it may also be possible that a data subject must provide us with personal data in order for a contract to be performed. Failure to do so would mean that the contract could not be concluded. Our employees will be happy to answer any questions you may have on a case-by-case basis.

The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

According to legal requirements, data is stored for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).

9. Web analytics

Use of Google Analytics 4

This website uses Google Analytics, a web analytics service provided by Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google Analytics is used by us to measure and analyse the use of our website. This is done exclusively on the basis of a pseudonymised user identification number, which is only used to assign analysis information to an end device. This makes it possible, for example, to assess which content has been accessed. The following data is also processed:

Time of utilisation
Duration of use
Technical details regarding the end device and browser It is not possible to link the data directly to individuals.

In addition, a special function (demographic characteristics) enables the creation of statistics relating to the age, gender and interests of users. This enables us to target marketing measures to specific groups. However, the data collected is not personally identifiable and is deleted after two months.

Google Analytics 4 also uses cookies in some cases. These are text files that are stored on your end device and enable your use of the website to be analysed. The information generated by the cookie about your use of this website may also be transmitted to a Google server in the USA and stored there. However, no individual IP addresses are processed for users from the EU. Nevertheless, rough geographical location data is processed.
We use Google Analytics to analyse and regularly improve the use of our website. We can use the statistics obtained to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the Trans-Atlantic Data Privacy Framework. The legal basis for the use of Google Analytics is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a DSGVO.
Information from the third-party provider: Terms of use: https://www.google.com/analytics/terms/de.html, overview of data protection: https://www.google.com/intl/de/analytics/learn/privacy.html, and the privacy policy: https://www.google.de/intl/de/policies/privacy.
You can make an objection (opt-out) via the plugin under the following link: https://tools.google.com/dlpage/gaoptout?hl=de
Of course, we have concluded a contract with Google for order processing.

10. Online advertising

1. Use of Google Ads Conversion

(1) We use the Google Ads service to draw attention to our attractive offers with the help of advertising material (so-called Google Ads) on external websites. We can determine how successful the individual advertising measures are in relation to the advertising campaign data. We are interested in showing you adverts that are of interest to you, making our website more interesting for you and achieving a fair calculation of advertising costs.

(2) These adverts are delivered by Google via so-called "ad servers". For this purpose, we use ad server cookies, through which certain parameters for measuring success, such as the display of adverts or clicks by users, can be measured. If you access our website via a Google advert, Google Ads will store a cookie on your PC. These cookies generally lose their validity after 30 days and are not intended to identify you personally. The unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wishes to be addressed) are usually stored as analysis values for this cookie.

(3) These cookies enable Google to recognise your internet browser. If a user visits certain pages of an Ads customer's website and the cookie stored on their computer has not yet expired, Google and the customer can recognise that the user clicked on the ad and was redirected to this page. A different cookie is assigned to each Ads customer. Cookies can therefore not be tracked via the websites of Ads customers. We ourselves do not collect and process any personal data in the aforementioned advertising measures. We only receive statistical analyses from Google. These analyses allow us to recognise which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material; in particular, we cannot identify users on the basis of this information.

(4) Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: Through the integration of Ads Conversion, Google receives the information that you have accessed the corresponding part of our website or clicked on an advert from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, there is a possibility that the provider will find out your IP address and store it.

(5) You can prevent participation in this tracking process in various ways: a) by setting your browser software accordingly, in particular suppressing third-party cookies will prevent you from receiving ads from third-party providers; b) by deactivating cookies for conversion tracking by setting your browser to block cookies from the domain "www.googleadservices.com", https://www.google.de/settings/ads, whereby this setting will be deleted if you delete your cookies; c) by deactivating the interest-based ads of the providers that are part of the "About Ads" self-regulation campaign via the link https://www.aboutads.info/choices, whereby this setting will be deleted if you delete your cookies; d) by permanently deactivating them in your Firefox, Internet Explorer or Google Chrome browsers under the link https://www.google.com/settings/ads/plugin. We would like to point out that in this case you may not be able to use all the functions of this website to their full extent.

(6) The legal basis for the processing of your data is Art. 6 para. 1 sentence 1 lit. f DSGVO. Further information on data protection at Google can be found here: https://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/de.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at https://www.networkadvertising.org Google has submitted to the Trans-Atlantic Data Privacy Framework.

2. Remarketing

In addition to Ads Conversion, we use the Google Remarketing application. This is a process with which we would like to address you again. This application enables our adverts to be displayed to you when you continue to use the internet after visiting our website. This is done by means of cookies stored in your browser, which are used by Google to record and evaluate your user behaviour when you visit various websites. This enables Google to recognise your previous visit to our website. According to its own statements, Google does not

merge the data collected in the context of remarketing with your personal data, which may be stored by Google. In particular, according to Google, pseudonymisation is used in remarketing.

11. Plugins and tools

1. Google tag manager

Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus integrate Google Analytics and other Google marketing services into our online offering, for example). The Tag Manager itself (which implements the tags) does not process any personal user data. With regard to the processing of users' personal data, please refer to the following information on Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.

2. Cookiebot

We use "Cookiebot" as a "cookie banner". "Cookiebot" is a product of Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark, hereinafter referred to as "Usercentrics".
Through the "Cookiebot" function, we inform the user about the use of cookies on the website and enable the user to make a decision about their use.
If the user consents to the use of cookies, the following data is automatically logged by Usercentrics:

The anonymised IP number of the user;
Date and time of consent;
User agent of the end user's browser;
The URL of the provider;
An anonymous, randomised and encrypted key.
The user's authorised cookies (cookie status), which serves as proof of consent.

The encrypted key and the cookie status are stored on the user's end device using a cookie in order to establish the corresponding cookie status on future page views. This cookie is automatically deleted after 12 months.
The cookie is used to fulfil a legal obligation on the basis of Art. 6 para. 1 lit. c DSGVO and our legitimate interest pursuant to Art. 6 para. 1 lit. f DSGVO. The legitimate interest lies in the user-friendliness of the website and in the fulfilment of the legal requirements of the GDPR (DSGVO).
The user can prevent or terminate the installation of cookies and their storage, and thus their cookie consent, at any time by changing their browser settings. Usercentrics offers further information under the following link: https://www.cookiebot.com/de/privacy-policy/