Privacy Policy

(Terms of Personal Data Processing)

Last update: 24/02/2020

1. Definition of concepts

1.1. Personal data is any information relating to an identified or identifiable individual. An identifiable natural person is an individual that can be identified directly or indirectly, in particular using identifiers, such as a name, identification number, location data, online identifier or one or more factors that are determining to physical, physiological, genetic, mental, economic, cultural or social nature of such an individual.

1.2 The database of personal data is a named set of ordered personal data in the electronic form and/or in the form of personal data files.

1.3 Personal data processing is any operation or a series of operations with personal data or sets of personal data using or not using automated tools, such as collection, registration, organization, structuring, storage, adaptation or modification, search, acquaintance, use, disclosure by means of transmission, distribution or provision in another way, arrangement or combination, restriction, erasure or destruction.

1.4 The owner (controller) of personal data is a natural or legal person who defines the purpose of personal data processing, establishes the composition of this data and the procedures for its processing.

1.5 The administrator (operator) of personal data is a natural or legal person who has been entitled to process the data on the owner's behalf by the owner of personal data or by law.

1.6 Profiling is any form of automated processing of personal data consisting of the use of personal data for the assessment of individual personal aspects relating to an individual, in particular, for analyzing or predicting aspects related to the performance of the data subject (natural person) at work, this person's economic situation, health, personal preferences, interests, reliability, behavior, location or movement.

1.7 All other terms and concepts used in this Policy are similar to the terms and concepts used in the main text of the User Agreement located at the following link: ("Agreement") or comply with the terms contained in the legislation.

1.8 When used in this Policy, the word "you" in all forms shall mean "User".

1.9 When used in this Policy, the word "we" in all forms shall mean "Company".

2. General provisions

2.1 The Company that owns TravelPost online platform is committed to maintaining the security of the Service Users' data. In order to ensure a legitimate, lawful and transparent way of using the Users' personal data and in order to ensure the proper security of the User's personal data, the Company has developed this Privacy Policy. This Privacy Policy ("Policy") is an integral part of the User Agreement ("Agreement") located at the following link: . By concluding the User Agreement and using the Service and Services provided by the Company, the User expresses his/her consent to this Policy. In case the User refuses to comply with this Policy, s/he shall discontinue to use the Service.

2.2 This Privacy Policy establishes the procedure for receiving, storing, processing, use and disclosure of personal data of the User of TravelPost information platform and Website (collectively, "Service").

2.3 In order to register in and use the Service (which includes publishing any information permitted by the Service functions and otherwise using the Service in accordance with the User Agreement), the User shall become familiar with this Privacy Policy and give his/her full consent to its terms by clicking the "Sign Up" button in the Service.

2.4 By registering in the Service and entering personal data and/or providing this data in another way and/or performing any actions within the Service and/or using any part of the Service, the User gives his/her unequivocal consent to the terms of this Privacy Policy. The User grants the Company the right to receive, store, process, use and disclose the personal data of the User under the terms of this Privacy Policy.

2.5 This Privacy Policy does not regulate and the Company is not responsible for the receipt, storage, processing, use and disclosure of personal data of the User by third parties who are not owned or managed by the Company and natural persons who are not employees of the Company, even if the User has obtained access to the websites, goods or services of these persons through the Service, the Website or the newsletter, as provided for in paragraph 2.8. of the Agreement.

2.6 The User acknowledges that in case of his/her negligent treatment of the security and protection of his/her personal data and authorization data, third parties may obtain unauthorized access to the Account as well as to personal and other data of the User. The Company shall not be liable for damages caused to the User by such unauthorized access.

2.7 By accepting the terms of this Privacy Policy, the User grants the Company a consent to include him/her in its TravelPost service Users Database of Personal Data.

2.8 The Users shall realize that, when going at certain links located on the Website or in the Mobile Application, they may be redirected to the websites (with applications etc.) of other companies outside the hosting area of the Company where the information about the Users is collected without the direct control of the Company. In this case, the Privacy Policies of third-party websites and/or applications shall govern the processing of information received from users by these third parties.

3. Information about a person who defines the purpose of processing personal data and processes the personal and other data of the User

3.1 The owner and administrator of the Database of Personal Data of natural persons who are the Users of the TravelPost Service are LTECH LLC, a legal entity registered under the legislation of Ukraine, the code of the USREOU (Unified State Register of Enterprises and Organizations of Ukraine) 41597032, location: Lutsk city, 2 Naberezhna St., office 149 ("Company"). The personal data of natural persons who are TravelPost Service users is processed by the Company.

3.2 The Database of Personal Data of the Service Users is stored on secure servers located in Ireland.

4. Information collected and processed by the Company

4.1 There are three general types of information that is collected and processed by the Company.

4.2 Information provided by the User to the Company.

4.2.1 Information that is necessary for using the Service. The Company requests and collects the following personal information (personal data) about you when you as a User use the Service. This information is necessary for the proper implementation of the Agreement between you and the Company for the proper functioning of the Service. Without such information, the Company will not be physically able to provide the Services/Service to the User.

  • Information on the registration of the User. When the User creates his/her Account in the Service, the Company asks to provide the required information necessary for the registration of the User in the Service. This information includes your name, surname and phone number. Please note that, based on your phone number, the Company automatically determines your country of residence. If you contact us using the feedback form in the Service, we will ask you to provide your email address so that you can receive an answer from us.

  • Information about Advertisements. To use certain features of the Service (for example, creating an Advertisement), we may ask you to provide additional information that may include the Traveler's Trip (the vehicle you are about to use, the route, departure and arrival dates), the photo and description of the contents of the Sender's Parcel.

  • Communication with us or other Users. When you contact us or other Users through the Service, for security purposes, we collect information about your communication and any information you want to provide.

4.2.2 Information provided to the Company by the User at his/her own choice. You may provide us with additional personal information (personal data) in order to obtain better service for Users or a higher User rating when using the Service. This additional information shall be processed based on your agreement. By uploading this information, you give us your permission to process such data. You have the right to revoke your consent to processing such data by deleting certain information from your Account.

  • Additional information about the User Account. You can provide additional information that is part of your profile in the Service (for example, a photo, a preferred language, currency, email address or short biography). Some of the information specified in the Account settings is part of your public profile page and will be open to others. The card or bank account number is required to get opportunity to receive payments through TravelPost.

  • Information about confirmation (identification) of the person. To help create and maintain a secure environment in the Service, the User may specify in his Account a link to the User Account on Facebook or Google, which contains the details of his or her identity confirmation. By registering in the Service, or by logging in (authorization) to the Service with the help of social network authentication services, the User gives the Company his/her consent to the collection and processing of information available from the respective profiles on the social networks. We do not receive any additional information about you from Facebook or Google other than your profile ID on these social networks, but other Users of the Service can see that your Account in the Service is verified using your account on Facebook or Google.

  • Other information. The User may provide information to the Company by completing a form in the Service, by searching the Service, by updating or adding information to his/her Account, by participating in a survey that may be conducted both by the Company and by the Company's contractors, by posting in the community forums of the Service, by participating in promotions or by using other functions of the Service.

4.2.3 The information we collect automatically about your use of the Service or the Website.

When the User uses the Service or visits the Website, we automatically collect information, including personal data, about the Services that the User uses and how they are used by the User. This information is necessary for the proper implementation of the Agreement between the User and the Company and in order to enable us to fulfill the obligations imposed on us by the Agreement. It will also enable us to provide and improve the functionality of the Service. This data helps us inform you about our Services, maintain a secure environment between Users and evaluate the effectiveness of the promotional messages we send to Users.

  • Information on using the Service. We collect information about your interaction with the Service, such as viewing the relevant sections and the Service Content, your searches in the Service for published Advertisements, the Advertisements you have posted, and other actions related to the use of the Service.

  • Log files and information about the User's device. We automatically collect log files and information about the device that you use when accessing the Service or the Website, even if you have not created an account or have not been authorized in the Service. In particular, this information includes IP address information, date and time of access/login to the Service, hardware and software information, unique identifiers and pages you have viewed or interacted with before or after using the Service.

  • Cookies, mobile identifiers and similar technologies. The Company uses cookies and other similar technologies, such as web beacons, pixels and mobile identifiers. We may also allow our business partners to use these tracking technologies in the Application or engage other contractors to track your behavior on our behalf. To learn more about our use of these technologies, see Section 10 "Cookies and other related technologies" of the Policy.

4.2.4 Information we receive from third parties.

We can collect information, including personal data, that others provide about you when they use the Service. We can also receive information from other sources and combine it with the information we collect using the Service. We do not control, supervise and are not liable for the way in which third parties providing your data process your personal data, and any information request regarding the disclosure of your personal information to us shall be directed to such third parties.

  • Feedback about you. If someone leaves a Feedback about you, it will be posted on your public profile page of the Service.

  • Other sources. Within the limits permitted by applicable law, we may receive additional information about you, such as fraud detection information, from third-party service providers and/or partners, and combine it with the information we have about you.

4.2.5 Information that is not collected or processed by the Company

  • The company does not collect or process personal data on racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, criminal convictions, as well as data relating to health, sexual life, or similar information.

  • We do not provide Services for children and do not process personal information relating to children. For the purposes of this Privacy Policy, "children" are people under the age of eighteen (18). Users shall be not younger than 18 to be able to use and register in the Service and receive the Services. We encourage you to talk with your children about the safe and responsible use of your and their personal data while browsing the Internet and using applications such as ours that involve engagement with strangers.

5. How long the Company retains the information collected

5.1 We can store your personal data until your User Account is active. We may keep your data longer if we cannot remove it for legal, regulatory or technical reasons. For example, in case of suspension or blocking of the User Account, we will store the User's personal data for the duration of the Service term in order to avoid any circumvention of the terms of the Agreement and the Service by the User.

5.2 The Company has the right not to store personal data of the User in case such User was not authorized in the Service within 2 (two) years.

6. How the Company uses the information it collects. Goals and purpose of personal data processing

6.1 We use, store and process information about you, including personal data, for the purpose of providing, improving the Service and Services, creating and maintaining a reliable and secure environment in the Service, providing, personalizing, analyzing and improving our advertising and marketing activities. In more detail, the aim and purposes of processing personal data are described in this Section.

6.2 Provision and improvement of the Service

  • Provision of access to and use of the Service

  • Provision of communication between Users in the Service

  • Use, protection, enhancement and optimization of the Service and the algorithm of interaction with the User, for example conducting analytics and research.

  • Sending service messages or support messages, updates, security notifications and Account notifications.

  • If you provide us with information about your contacts, we may process this information: (1) for detecting and preventing fraud; (2) for any purpose you consent to when the information is being collected.

  • Ensuring the functioning, protection, improvement and optimization of the Service and the algorithm of interaction with the User, as well as personalization and improvement of user experience (for example, providing recommendations for the publication of Advertisements or the ranking of search results), implementation of profiling based on the interaction of the User with the Service, the history of use of the Service, information about your profile, other information that you provide to the Service and information we receive about you from third parties.

We process the information in the light of our legitimate interest in improving the Service and the algorithm of interaction between the Service with the User, as well as for the proper implementation of the Agreement or on the basis of your consent.

6.3 Creation and maintenance of a safe and secure environment in the Service

  • Detection and prevention of fraud, spam, abuse, security breach and other actions that may harm the Company, other Users or third parties.

  • We process this information in the light of our legitimate interest in protecting our Users and the Service in order to take steps to properly implement the Agreement with you and to comply with applicable law.

  • Conducting safety investigations and risk assessments.

  • Checking, verification, authentication or identification of the data provided by you.

  • Conducting inspections based on databases and other information sources within the limits permitted by the current legislation and with your consent where necessary.

  • Compliance with our legal obligations.

  • Resolution of any disputes with any of our Users and enforcing treaties and agreements with third parties.

  • Ensuring implementation of the Agreement and the annexes thereto.

In connection with the above actions, we may conduct profiling based on User's interaction with the Service, the history of use of the Service, information about your profile, other information that you provide to the Service and information we receive about you from third parties. In some cases, automated processes may restrict or suspend access to the Service if such processes detect the User or activities that we believe represent a security or other risk for the Service, other Users or third parties.

6.4 Provision, personalization, measurement and improvement of the effectiveness of the Company's advertising and marketing activities

Sending to the Users the promotional messages, marketing, advertising and other information that may interest the User in accordance with the User's preferences (including information about the activities of the Company and Service and advertising on social networks through social media platforms such as Facebook or Google).

  • Personalizing, measuring and improving the effectiveness of the Company's advertising.

  • Administering surveys, conducting contests as well as other advertising activities relating to the Service, which may be carried out both by the Company and its contractors.

  • Performing profiling based on your characteristics and settings (based on your information, the interaction with the Service and the Website, information received from third parties, and the history of the search and use of the Service) in order to send you promotional messages as well as marketing, advertising and other information that we think may be of interest to you.

We will process your personal data for the purposes listed in this section based on our legitimate interest in advertising and marketing activities in order to offer you products or services that may be of interest to you or based on your consent.

You may refuse to receive promotional messages from us, following the unsubscription instructions contained in such promotional messages, or change the notification settings in your Account or on your device that you use to access the Service.

7. User's rights with respect to the data protection

7.1 You can exercise any rights described in this section by sending us an email to . Please note that we may ask you to confirm your identity before taking any further action on your request. In addition, some of the following rights are provided by law only in some jurisdictions. That is why in some cases, we will need to check your residence to meet your request.

7.2 Management of your information (personal data)

You have access and opportunity to update some User information (data) in your Account settings. You are responsible for the storage of your personal information.

7.3 Correcting inaccurate or incomplete information

You have the right to request us to correct inaccurate or incomplete personal data about you (which you cannot update within your Account settings).

7.4 Access to data and a right to data mobility

In some jurisdictions (for example, in the European Economic Area), applicable law may give you the right to request a copy of your personal data that we retain. You also have the right to request a copy of personal information that you provided to us in a structured, generally accepted and machine-readable format and the right to transfer such data to another Owner (controller) of personal data.

7.5 Saving and deleting data. "The right to be forgotten"
We usually store your personal data to the extent necessary to implement the Agreement and to comply with our legal obligations. If you no longer want us to use your personal data, you can ask us to remove your personal data and delete your Account. Please note that if you are requesting the removal of your personal data:

  • We may retain some of your personal data that is necessary for our legitimate business interests, such as detection and prevention of fraud and security enhancement. For example, if we suspend the Account in order to detect or prevent fraud or for other security reasons, we may retain certain information about this Account in order to prevent the same User from creating another Account in the Service in the future.

  • We may retain and use your personal data to the extent necessary to fulfill our legal obligations. For example, the Company may retain some of your information for legal reporting and auditing responsibilities, if any.

  • Information that you provided to another person (for example, Feedback, posts, chats in the Service) may remain public on the Service, even after your Account is deleted. However, such information will be considered impersonal, since it will not contain references to the specific User Account. In addition, some copies of your information (such as log files) may remain in our database, but such information will be considered impersonal since it is impossible to identify a particular person based on such data.

  • Since the Service is protected from accidental or harmful loss and destruction of information, the remainder of your personal data may not be removed from our backup systems for a limited period of time.

7.6 Withdrawal of consent

If you have given the Company your consent to the processing of your personal data, you may at any time cancel your consent by changing your Account settings or by sending us a request through the support form in the Service, specifying which kind of consent you wish to revoke. Please note that withdrawal of your consent does not affect the legality of any data processing on the basis of such consent prior to its withdrawal.

7.7 Restrictions on the processing of data

In some jurisdictions, the relevant legislation may give you the right to restrict the use of your personal data, in particular if: (1) the accuracy of personal data is disputed over a period of time, which gives the controller the ability to verify the accuracy of personal data; (2) the processing is illegal, you are against erasing your personal data and instead request that its use be restricted; (3) the controller no longer needs personal data for the purpose of processing, but you require them for the formation, implementation or protection of legal claims; (4) you have objected to the processing of personal data, and there is an inspection pending as to whether the legitimate grounds of the controller prevail over your legitimate interests.

7.8 Objection to processing

7.8.1 In some jurisdictions, the applicable law may give you the right to require us to process your personal data for specific purposes (including profiling) if such processing is performed on the basis of legitimate interests. If you object to such processing of personal data, we will no longer process your personal data for these purposes unless we can demonstrate the reasonable legitimate grounds for such processing, or such processing is necessary for the establishment or satisfaction of legal claims.

7.8.2 If your personal data is processed for direct marketing purposes, you can at any time ask us to stop and object to the processing of your data for direct marketing purposes by sending us a request through the contact support form in the Service.

7.9 Filing complaints

If you have implemented any or all of your data protection rights and still are concerned about how we use your personal data or you feel that we have not properly fulfilled our obligations regarding personal data, you have the right to file a complaint by sending an email to You also have the right to file a personal data processing complaint with the competent personal data protection authority in your country.

8. Disclosure of information to third parties

8.1 Information exchange between Users.

In order to improve the publication of Advertisements or other interaction between Users, we may need to provide certain information, including personal data, to other Service Users as it is necessary for the proper implementation of the Agreement:

  • When you, as a Sender, post a Parcel delivery request, certain information about you is provided to third parties, including your full name, description of your Parcel, and other information you agree to provide. When your request is confirmed, we will disclose additional information that will help you coordinate the interaction between you and the Traveler, for example, your phone number.

  • When you, as a Traveler, post a Travel Advertisement, we will show you the suggested Parcel delivery offerings that may fit your route. Also, some information about you, including contact information, is provided to the Sender who has chosen your offer.

8.2 Profiles (Accounts), Advertisements and other public information

The Service allows publishing information, including personal data, which is accessible to other Users. Here are some examples:

  • Some of the information on your public profile page, such as your full name, a photo of your public profile, and your Rating, are publicly available to others.

  • Advertisements that are publicly available.

  • After a Parcel is delivered, Travelers and Senders can leave Feedback about each other.

8.3 Compliance with the law, responding to legal claims and prevention of damage to and protection of the rights of the Company

8.3.1 We may disclose your information, including personal data, to the courts, law enforcement authorities or other public authorities or authorized third parties to the extent that we are required or permitted to do so by law, or if such disclosure is justified and necessary for: (1) compliance with our legal obligations; (2) taking part in a lawsuit and responding to claims filed against the Company; (3) responding to legal inquiries related to a criminal investigation or a potential threat by illegal activities or any other activity that may harm the Company, the User or a third party; (4) enforcing the Agreement or other agreements with the Users, or (5) protecting the rights and property or ensuring personal security of the Company, its employees, its Service Users, or third parties.

8.3.2 Such disclosure may be required to comply with our legal obligations, to protect your vital interests or another person, or for the purpose of protecting our or a third party's legitimate interest in order to protect the Service and prevent any harm or crime, the exercise or protection of legitimate rights.

8.3.3 In appropriate cases, we may notify Users about legal requirements, except in case: (1) the provision of such notice is prohibited by the lawsuit itself according to a court decision or relevant legislation; (2) we believe that providing such notice will be useless, ineffective, or may create risks or threats to other people, the Service and the Company. In cases when we respond to legal claims without warning for these reasons, we will endeavor to inform this User about this request post factum, when appropriate and when we will clearly acknowledge that we will no longer be banned from doing so.

8.4 Service Providers

We engage such third parties as service providers so that the Company could provide the Services relating to the use of the Service. Such service providers may be located within or outside of the European Economic Area. Such service providers, for example, including, but not limited to, may provide support to our Website, Service and Services, in particular regarding hosting and Website/Service management, marketing, analytics, Website/Service improvement and distribution of email newsletters. In such circumstances, recipients of personal data may include, for example, external consultants, financial and business consultants; auditors and accountants; marketing and advertising specialists; file storage companies, archiving and/or document management companies, cloud storage companies; companies that help us effectively provide our Services to you by providing technical examination, solutions and support; web studios and advertising agencies. These providers have limited access to your information to perform these tasks on our behalf and, under the terms of the agreement, are required to protect and use your information only for the purposes for which it was disclosed and complies with this Privacy Policy.

8.5 Business Transfer

If our Company is involved in any merger, consolidation, division, reorganization, acquisition, sale of assets, bankruptcy or insolvency, we may sell or transfer a part or all of our assets, including your information, in connection with such a transaction or in the process of considering such a transaction (for example, due diligence). In this case, we will notify you before the transfer of your personal data.

8.6 Data transfer to other countries

To optimize our global operations, we may transfer, store and process your information, including personal data, through service providers located in other countries. The laws in these countries may differ from the laws applicable to your country of residence. For example, information gathered within the EEA may be transmitted, stored and processed outside the EEA for the purposes described in this Privacy Policy. When we transmit data and process your personal data outside the EEA, we will provide appropriate safeguards to ensure an adequate level of data protection.

9. Other important information

9.1 User communication analysis

We may review, investigate, or analyze your messages in the Service for the prevention of fraud, risks assessment, compliance with laws, investigations, products development, research and customer support. For example, as part of our fraud prevention efforts, we investigate and analyze messages that hide the true description of Parcels with prohibited objects. In some cases, we may also investigate, review or analyze messages to improve and expand our offerings relating to the provision of Services. We use automated methods, where possible. However, sometimes we may need to review some messages independently, for example, to investigate fraud and provide support to Users as well as to evaluate and improve the functionality of these automated tools. We do not investigate or analyze your communications to send out third-party marketing messages, and we shall not sell or alienate otherwise such research or analysis of these messages.

These measures are based on our legitimate interest in ensuring compliance with applicable law and our Terms of Use, preventing fraud, enhancing security and improving and ensuring the proper operation of the Service and the provision of the Services.

9.2 Linking third party accounts

You can link your Account in the Service with your account in a third-party social network. When creating such a connection, we will receive your account identifier in such a social network, and other Users of the Service will see that your Account in the Service is verified by reference to your external account in the social network.

10. Cookies and similar technologies

10.1 When you use the Service or visit the Website, our system automatically collects information about your visits, such as your browser type, the operating system used by you, and your IP address. This information is usually collected using cookies, pixels, beacons, built-in hyperlinks and similar tools.

10.2 In addition, we use cookies and pixels to personalize content and advertisements, as well as to analyze the audience of the Service. Some of these cookies and similar technologies are hosted through our Website and Service by third-party service providers with whom the Company has entered into an appropriate contract or agreement.

10.3 Cookies are text files that contain a small amount of information that is downloaded to your device when you visit the Website or use the Service. Cookies can be recognized by the website (or app) that downloaded them or by other websites that use the same cookies. This helps websites to find out whether they have been visited by the device before. Cookies allow the website to memorize your actions or preferences over a period of time.

10.4 Pixels are tools that allow you to track user actions on a website or in a program and collect information about these actions. Data collected from pixels can be used for advertising and marketing campaigns.

10.5 The following are the types of cookies and similar technologies we use on the Website and in the Service with the following purpose:

  • Mandatory cookies provide navigation and basic features of the Service and the Website, for example, the access to the secure area of the Service.

  • Functional cookies allow you to analyze the use of the Service and the Website and your choice (for example, your language settings or your country) so that we could keep these settings and offer you a more personalized approach.

Mandatory and functional cookies are the main cookies that belong to us and are installed by the Website or the Service. All information collected by these cookies is anonymous and is used only to ensure the proper functioning and improvement of our services.

  • Some third-party cookies are hosted on your device through the Website or Service by other organizations, such as third-party analytics or advertising companies. Such third-party organizations may use cookies, beacons, pixels and other technologies to collect and receive information from us and other countries on the Internet to provide analytics services for visiting statistics (Google Analytics) and targeted ads (Facebook Pixel, Facebook Custom Audience). We ask you to give us your consent to use these cookies on the Website and in the Service.

  • You can choose to have your device alert you whenever cookies are sent, or you can turn off all cookies. You can do this through the settings of your browser. Check out the help menu of your browser to find out the correct way to configure cookies.

  • To opt out of Google Analytics tracking on all websites, please visit .

  • To specify your advertising preferences on Facebook, in particular, to turn off personalized ads, please visit the page

11. Security

We are constantly implementing and updating administrative, technical and physical security measures to protect your information, including personal data, from unauthorized access, loss, destruction or alteration. Some of the safeguards we use to protect your information are firewalls, data encryption and information access control. If you know or have reason to believe that your Account data was lost, stolen, misappropriated, or your data protection rights were otherwise infringed, or in the case of any actual or suspected unauthorized use of your Account, contact us at the e-mail address

12. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will publish the revised Privacy Policy in the Service and on our Website and provide the last updated date at the top of this Privacy Policy. We will also send you a notice in the Service about making changes to the Policy at least 30 (thirty) calendar days prior to the effective date of the Policy. If you do not agree to the revised privacy policy, you must stop using the Service. If you do not cancel your Account before the effective date of the revised Privacy Policy, your continued access to the Service or use of the Service will be governed by the revised Privacy Policy.