Legal Agreements

TTRS Online Privacy Policy

This Privacy Policy was published on 04/25/2022 and last updated on 11/14/2024.

Introduction

Welcome to the Touch-type Read and Spell (TTRS) privacy policy.
TTRS respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please note that if you are in the European Economic Area, United Kingdom, Switzerland or any other country that the EU General Data Protection Regulation 2016/679 (“GDPR”) and Data Protection Act of 2018 (DPA), you will not be required to consent to this policy, however, by using TTRS, you acknowledge that you have read and understood its terms.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how TTRS collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.

About Us

We are Touch-type Read and Spell Limited (registered in England & Wales under registration number 02944581) (referred to as "TTRS”, "we", "us" or "our" in this privacy policy). We are dedicated to the privacy of our website and platform visitors and Users. We are committed to protecting and safeguarding your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Touch-type Read and Spell Limited

Name or title of data privacy manager: Peter Driver

Email address: support@readandspell.com

Postal address: TTRS Administration, Chislehurst Business Centre, 1 Bromley Lane, Chislehurst, Kent BR7 6LH, United Kingdom

Telephone number: +44 (0)20 8144 1964

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues ( www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Uploading by Tutors of personal data regarding Clients (in particular Minors)

From time to time personal data regarding our clients may be uploaded to our website by tutors who have contracted with us (Tutors) or by others with access to the website. Under the functionality of our website only the following information is to be provided in respect of a client: first name, last name, username, password, email address (optional) and selected avatar (optional).

This functionality is made available to Tutors and such others via our website on the condition that the relevant Tutor or other person has taken all reasonable steps to prove that the client is aged eighteen (18) or over and for all clients under the age of eighteen (18) the Tutor or other person has obtained the full and effective consent of the parent or guardian, as applicable, prior to any personal data being uploaded to such uploading occurring and to all matters as provided in the privacy policy. Uploading any such personal data in respect of clients under the age of eighteen (18) is deemed to be an undertaking by the relevant Tutor or another person to TTRS that such consent has been obtained. Our website may not be accessed by any persons other than pursuant to a licence issued by us.

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on March 2022 and historic versions can be obtained by contacting us at support@readandspell.com.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

We do not sell any data - personal, anonymous or aggregated to advertisers. We also refrain from using data for targeted advertising aimed at children. We do not create or maintain personal profiles of students, except when necessary to support approved educational purposes or when explicitly authorized by a parent, school or educational institution.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier
Contact Data includes billing address, delivery address, country, time zone, email address and telephone numbers and school.
Financial Data - we do not store credit card or financial details. Payment information is not stored by us but is stored securely with our Payment Processors (Stripe or Paypal) Our payment processors also collect and retain information related to your transaction.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services, chat messages between client and Tutor
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of Users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you provide this information to us, we might not be able to protect such information. Please know that we will in no circumstance ask for this special category of personal data information

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions - You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for our products or services;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.

Automated technologies or interactions - As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.

Recording and storing of use of the website - We also may record and store copies of your activities on our website using our own or third-party products or software. This functionality allows us to watch a DVR-like video playback of User sessions on the website. This gives us insight into our Users' experience and is an effective way to identify usability problems and other areas for improvement. The usage data we collect in this manner may include information on your use of our website, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information more commonly collected such as the referring URL, browser, operating system, cookie information, Internet Service Provider and Internet Protocol address. We do not monitor or check the personal messages between teachers and students. However, we may be required to access this information for support, compliance and dispute resolution purposes. Before we do, we will obtain the permission of one of the parties to access such information.

If you do not wish us to record and/or store copies of your activities on our website using our own or third-party products or software please write to TTRS Administration, Chislehurst Business Centre, 1 Bromley Lane, Chislehurst, Kent BR7 6LH, United Kingdom or email us at support@readandspell.com stating this.

Third parties or publicly available sources - We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

analytics providers such as Google based outside of the EU
advertising networks
search information providers

Contact, Financial and Transaction Data from providers of technical, payment and delivery services

Data processors such as JotForm based inside of the EU
Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Email marketing tools based in the EU

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us here.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us here if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including the basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us [or if you provided us with your details when you entered a competition or registered for a promotion] and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the TTRS group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contact us at any time.

Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

All Users under the age of 18 are not included in our marketing campaigns, we automatically opt-out all Users under the age of 18 from our marketing communications and promotional offers.

5. COOKIES

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see below:

A cookie is a small file that asks permission to be placed on your computer's hard drive. By logging into our site, you agree for us to use cookies. Cookies help analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

The first time you visit our Website, you will be informed about our use of cookies to improve your website experience. Consenting to our use of cookies in accordance with the terms of this Policy when you first visit our Website permits us to use cookies every time you visit our Website. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Why do we use cookies on our website?

We use the following cookies to optimize your experience on our site and to provide our services.

Functional– These cookies allow us to analyse your use of our website, product and services when you return to our website, this helps us to evaluate and improve our system performance. We use cookies to improve your experience by remembering your preferences, so we know how you like to use our website.
Performance– These cookies are necessary to enable the basic features of this site to function, some of these features include but are not limited to providing secure log-in. These cookies are required for the operation of our Platform.
Targeting activities– Targeting cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Advertising and Marketing– To ensure that the adverts and marketing campaigns that you see are relevant to you we use cookies to collect information about the types of things that interest you.
Analytical– We use analytical/performance cookies to help us understand how Users engage with our website. An example is counting the number of visitors and seeing how many visitors move around our website when they are using it. This helps us to improve the way our website works, for example, ensuring that Users, such as yourself, find what you are looking for easily.
Third-Party Cookies- We use the following third-party services for analytics, advertising and marketing. We suggest that you take a look at the privacy and data policies of these platforms to help you know how they use your data. Specifically, we work with analytics providers such as Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. Google Analytics may also collect information regarding the use of other websites, apps and online resources. Please see google policies, or you can opt out by downloading Google’s opt out addon - the Google Analytics opt-out browser add-on.
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Managing your cookies preferences

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can always manage your cookies and tracking. You can do this through the settings in your browser. You can set your browser to inform you on accepting or rejecting cookies on a website you visit. If you use different devices in different locations to access our Platform, you should make sure that these devices are set to your preferences before accessing our Platform.

If you have previously consented to us storing cookies on your machine but then change your mind, you can delete the cookies from your browser or device. Most browsers also allow you to prevent all or some cookies being stored on your machine in the future. For adequate and accurate information on how to delete or disable cookies from your browser, please use the “help” function within your browser. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file.

For more information you can use also use the following link

Device	Managing Cookies
Chrome (Web and Mobile Devices)	Click Here
Safari (Web and Mobile Devices)	Click here
Firefox (Web and Mobile Devices)	Click Here
Internet Explorer	Click Here
Other Devices and Browsers	Please contact the help session of your device or contact the provider

If you only want to reject some or all of the third-party cookies, you will need to visit the relevant third party’s website directly to manage cookies stored on your machine by them.

Please be informed that disabling cookies may affect the functionality and accessibility of some pages on our Platform.

We can’t always control third party cookies stored on your machine from our website, setting your cookie preferences with us will not stop those third-party cookies from being stored on your machine. You must manage these cookies directly with the relevant third party. We suggest that you take a look at the privacy and data policies of these third parties to help you know how they use your data.

For further information about cookies, please visit the guidance on cookies published by the UK Information Commissioner’s Office at https://ico.org.uk/your-data-matters/online/cookies/

6. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA) other than as described below.

We have databases stored on servers operated by Microsoft Azure located in the Netherlands in the EU.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Further details can be found in our DPA ( https://www.readandspell.com/dpa )

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

9. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. DATA RETENTION

How long will you use my personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us

In some circumstances you can ask us to delete your data: see clause 8 below or contact us for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below. You have the right to:

The right to request access to your personal data (commonly known as a “data subject access request”): enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
The right to request correction of such personal data that we hold about you: this enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify the accuracy of the new information you provide to us.
Request erasure of your personal data: this enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
The right to object to the processing of your personal data, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms: You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
The right to request the restriction of processing of your personal data: this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
The right to request the transfer of your personal data to you or to a third party: we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
The right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. LAWS

Pertinent laws and requirements applicable to a particular User may vary depending upon multiple factors such as the country where the User resides or uses our website or system or a contract TTRS and the Administrator entered into for providing our program to the User as the Administrator’s Student. Laws we comply with include:

The Laws of England and Wales;
The Children's Online Privacy Protection Act (COPPA)
The Family Education Rights and Protection Act (FERPA);
The Protection of Pupil Rights Amendment (PPRA);
The Individuals with Disabilities Education Act (IDEA);
Several state laws of the United States that are identical or similar to federal data security laws;
General Data Protection Regulation (GDPR);
Data Protection Act (UK);

13. GLOSSARY

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

Service providers acting as processors as described in clause 6 above who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and New Zealand who provide consultancy, legal and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

14. DATA PROCESSING AGREEMENT

If you are a School Member, Home Member or Tutor within the use of our Service, to the extent that we process any Personal Information on your behalf for the provision of our Services, the terms of the Data Processing Agreement (including the EU Standard Contractual Clauses, the UK Addendum, the California Addendum and the Switzerland Addendum) at https://www.readandspell.com/dpa (“DPA”), which are hereby incorporated by reference, shall apply and you agree to comply with such terms.