Privacy Policy

Your security is our primary concern.

The respect for and maintenance of the personal privacy of users (“Users” or “you”) is of paramount importance to us. This website (“website” or “Site”) for Modiv Inc., a Maryland corporation (“Modiv” or “we” or “us”), collects certain personal information, including that which assists us in complying with state and federal laws, including securities laws. We do not disclose any nonpublic personal information about you to anyone except in the limited cases identified in this Privacy Policy (this “policy”).

We maintain technology and information management systems designed to protect the confidentiality and security of your nonpublic personal information. In addition, we restrict access to nonpublic personal information about you to personnel who have a legitimate business need for the information, or as otherwise required by law or permitted by this policy.

By using the Site, you consent to our collection and use of information as explained in this policy, and consent to be bound by the Terms of Use and other guidelines we publish on the Site, as amended from time to time.

What information we collect.

We may collect Personal Information from you or from other sources. “Personal Information” generally means information that might reasonably be used to specifically identify you and may include information such as:

Contact information, such as your name, postal address, email address, phone number and/or mobile number;
Demographic information such as gender, job information and company information;
Age and/or date of birth;
Financial information such as income level and net worth;
User name and password; and
Location data that describes the precise geographic location of your device (“Precise Location Data”).

We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this policy. The type of information we collect may change as technologies evolve. Other Information may include, but is not limited to, information such as:

Areas or topics of interest;
Content of messages or comments posted by you or other users (e.g., text, photos, videos, and links) to the Site, including on forums or content;
Browsing history, including the websites or other services you visited before and after visiting the Site;
Device type, settings and software used;
Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device, but is different than a hardware serial number;
Advertising ID, which is a unique, user-resettable identification number for advertising associated with a device (e.g. iOS uses the Identifier for Advertising (or “IDFA”) and Android uses Google Advertising ID);
Internet connection means, such as internet service provider (“ISP”), mobile operator, WiFi connection, service set identifier (“SSID”), International Mobile Subscriber Identity (“IMSI”) and International Mobile Equipment Identity (“IMEI”);
Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet;
Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links; Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies;
Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, are a method for passing information from the user’s computer to a third-party website; Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”);
Flash cookies and HTML5; and
Information collected through the use of cookies, eTags, Javascript, pixel tags, device ID tracking, anonymous identifiers and other technologies, including information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, the services and ads on third party websites, applications, platforms and other media channels, and (ii) your interaction with emails including the content and ads (collectively, “Online Data”).

We may also supplement the Personal Information and Other Information we collect from you with information from third parties, including third-party affiliate network operators, referral sources, social networking sites or services (such as Facebook, Twitter, and LinkedIn), and commercially available or public sources (such as data brokers, data aggregators and public databases).

If you use a third-party connection or log-in (such as Facebook, Twitter, or Google+) to create a membership or profile on any part of the services, access our content or forward our content to another person, platform or service, we may also receive your user name, password or email address for those third party services or other information available about you or collected from you on those services. This policy does not cover the practices of third parties, including those that may disclose information to Modiv.

How we collect and use information.

Modiv collects Personal Information and Other Information (collectively, “User Information”) as described herein. All information is or may be used as described in this policy.

We collect User Information via our Site, such as when you register for Site membership or create a profile or account on any part of the Site; invest in our offerings; sign up for emails, newsletters, bulletins, webinars or white papers; chat online; enter a sweepstakes, contest, competition or prize draw; receive promotional information by SMS text message; participate in surveys; perform search queries on the Site; or otherwise communicate with us. We also collect User Information about you offline through telephone or direct mail efforts or from customers, vendors, suppliers, third parties and publicly-available sources.

When you use the Site, we may combine Personal Information with Other Information we collect about you. We do this to improve services we offer you and to improve the functionality of the Site and our ability to market or advertise to you those products or services that may be of interest to you. We may also combine information you have provided to us with information obtained from other sources.

Personal Information is used to provide certain services to you from Modiv, its affiliated entities or its partners, which includes, but is not limited to when: (i) we send emails or newsletters offering services or products to you, (ii) you provide your personal testimonial for Modiv to post alongside other endorsements, or (iii) we display your personal reviews of products or services. Personal Information may also be used to send you advertisements and promotions regarding Modiv and/or its affiliated entities via the Site and on third-party channels. Personal Information you provide to us is used in a way that is compatible with this policy. The Site may use Personal Information of a registered user to “pre-populate” online forms that are displayed for the purpose of collecting additional information about you by the Site or on behalf of a third party.

Modiv and its partners use cookies and other tracking technologies to analyze trends, administer services, track users’ movements around the Site and on third-party sites, devices and applications, and to gather demographic information about our user base. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the Site.

Tracking technologies on the Site may be deployed by Modiv and its affiliated entities and/or by our service providers or partners. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Site to other information about you, including your User Information. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information for the purposes of learning more about you so we can provide you with relevant content and advertising.

When you receive email messages or newsletters from us, we may use web beacons, customized links, clear GIFs or similar technologies to determine whether the email has been opened and which links you click in order to provide you more focused email communications or other information, and/or aggregate with other data we collect for some or all of the purposes outlined in this policy.

We and our partners (including e-commerce partners, affiliates, and analytics providers) may also use technologies such as pixel tags, e-tags, IP addresses, Local Shared Objects, Local Storage, Flash cookies and HTML5 to analyze trends; administer the Site; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement to our server logs and other methods of traffic and response measurement; track users’ location and movements around the Site; gather demographic information about our user base; and to improve our understanding of traffic on the Site, visitor behavior, and responses to promotional campaigns. We may receive reports based on the use of these technologies by third-party companies on an individual and aggregated basis. For example, we may connect information about your IP address to known corporate or other information or User Information and use the associated information related to aggregate content preferences to assist in our efforts to market services to you or the originating organization(s). Various browsers may offer their own management tools for removing Local Storage.

The Site includes certain social media features, such as the Facebook “Like” button and widgets, which include the “Share” button or interactive mini-programs that run on the Site. These features may collect your IP address, track which page you are visiting on the Site, and may serve a cookie to enable the features to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy policy of the company providing it.

We may also use User Information collected from you in order to:

identify you as a potential client and confirm your identity, legal capacity and eligibility to invest in offerings posted on the Site;
establish and manage your account with us;
enable registered users to login to the Site;
communicate and share information with your IRA custodian and other similar parties acting at your request and on your behalf;
provide services and products requested by you;
market services and products offered by Modiv or its affiliates that may be of interest to you;
compile aggregate data for internal and external business purposes;
comply with legal and regulatory requirements;
guard against potential fraud, and help prevent potentially unlawful activity or activities that threaten the integrity of our Site or network;
protect and defend our rights or property or the rights or property of others;
meet legal requirements of courts or administrative agencies; and
engage in any other lawful activities we believe are consistent with the foregoing.

Information regarding interest-based advertising

Modiv, its affiliated entities and/or certain third parties may collect information about you for online behavioral advertising (“OBA”) purposes in order for you to receive relevant interest-based advertising on the Site and on other websites, platforms and media channels. OBA is also referred to as interest-based advertising.

Modiv displays ads on both the Site and on third party websites, applications, platforms and other media channels (collectively, “Channels”). We use Online Data as well as other User Information to send you OBA. For example, if you read an article about a particular subject on the Site, we may use cookies from a vendor to later serve you an advertisement for a particular product or service related to the viewed article. These third-party vendors may connect information about pages you visit on the Site with information about pages you visit on other Channels and show you advertising based on this combined information. These advertisements may appear when you are visiting a different section of the Site or on another Channel. Likewise, third-party vendors may serve you advertisements when you visit the Site based on your interaction with the Site and other Channels.

Online Data is aggregated with the other information and data we collect as described in this policy and/or similar data collected by partners to create groups of users and certain general-interest categories or segments that we have inferred based on (a) demographic or interest data and GeoIP Data, (b) the pages you view and links you click when viewing an email or using the Site and those of our partners, and/or (c) the search terms you enter when using certain search services. We use this information to get a more accurate picture of audience interests in order to serve ads we believe are more relevant to your interests. We store page views, clicks and search terms used for ad personalization targeting separately from your Personal Information.

We may also sell or transfer Online Data to certain third parties such as advertisers who will use this data to serve ads that they believe are relevant to your interests, and who agree to maintain the confidentiality of this information. Some of these third parties may combine the Online Data with their own data about you to form a more detailed picture.

We may engage third-party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. We do not authorize such third-party providers to collect Personal Information from our Site for their own purposes.

We may also engage third parties for the purpose of recognizing our users and delivering interest-based content and advertisements to them. We may share your User Information with our partners such as your name, postal address, email, or other identifier. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID, and information about your browser or operating system; (ii) combine User Information about you received from Modiv with information about you from other sites or services; and (iii) place or recognize a unique cookie on your browser.

We may use an ad network partner, who may use cookies, web beacons and advertising IDs to collect information about your activities on the Site and Channels to provide you targeted advertising based upon your interests. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. Should you opt out of interest-related ads, please note this does not opt you out of being served all advertising. If you opt out of interest-based ads, you will continue to receive ads, but these ads may not be as relevant to your interests. If you change your computer, change your browser, reset your advertising ID, or delete your cookies, you will need to renew your opt-out settings.

What information we give to third parties.

Modiv provides User Information to its affiliated entities, third-party companies and contractors who work on our behalf to provide us with specialized services, such as email message deployment, email address validation, merge-purge (identifying and removing duplicate addresses), investment fulfillment, customer support and service, research, statistical analysis, cross-device user tracking, data and website hosting, marketing, advertising, and other data and transaction processing. These companies work on our behalf, are authorized by Modiv to obtain only the information they need to deliver the service, and are required to maintain the confidentiality of the information. We also engage third-party service providers for the purpose of processing the sale of shares of our offerings, to fulfill the payment of dividends or repurchases, to honor your request to be removed from promotional mailings, or other services. These service providers have access to or are provided with certain Personal Information (including financial/banking information) in order to provide us with the applicable service.

In addition, we may disclose your personally identifiable information to the extent reasonably necessary to:

our affiliates, for the purposes identified above, subject to this policy;
help prevent potentially unlawful activity or activities that threaten the integrity of our Site or network;
protect our rights and property and the rights and property of others;
take precautions against liability;
respond to claims that your information violates the rights and interests of third parties;
meet legal requirements or to respond to judicial process, or as otherwise required by courts or administrative agencies; and
transfer such information to an acquirer, investor or successor in connection with a financing, sale, merger or reorganization of our business or assets.

Any successor in interest to our business would acquire the information we maintain, including nonpublic personal information, and may alter the terms of this policy.

How you can change or control what is collected.

Updating Your Information. Upon request, Modiv will provide you with information about whether we hold any of your Personal Information. If you wish to make any such request, or to correct, delete or change any personal information collected from you, please contact us directly by clicking on the appropriate link below (which should lead to a “Contact Us” page or support email) or contact us at support@modiv.com , (must include “Privacy Policy” in the subject line) and we will respond to your request within a reasonable timeframe.

Cookies and Pixel Tags. You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Site, you may not be able to use all of the features, functions, or services available on the Site.

Your Newsletter and Email Subscriptions. You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. For some Site-supported services, member service-related communications are an integral part of such services to which you subscribe and you may continue to receive emails as part of that particular portion of the services unless you cancel your account, even if you opt out of the newsletters or email list.

Text Messages. You further expressly consent to receiving periodic text or SMS messages using an autodialer regarding your account or transactions you have made and marketing messages regarding our products and services to the mobile phone number provided when you register for our services. Consent is not necessary to purchase any products or services. Message and data rates apply. You may opt-out of such text or SMS messages by replying STOP. Text HELP for assistance.

Please note that you may not opt out of any future contacts from us that are required by law or necessary for Site administration.

How this policy can change.

From time to time, we may change this policy. We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this policy at any time. Any changes or updates will be effective immediately upon posting to the website. You should review this policy regularly for changes, and can determine if changes have been made by checking the Effective Date below. Your continued use of our Site following the posting of any changes to this policy means you accept such changes.

Links to Other Web Sites

This website may contain links to other websites. We are not responsible for and shall not have any liability arising from the privacy practices or the content of other websites.

Do Not Track Requests

You may be able to adjust your browser settings or other settings so that “do not track” requests are sent to the Site. Our Site does not currently respond to such requests.

Security

We take reasonable measures to protect the information you provide to us against loss, theft, unauthorized use, disclosure or modification. However, we cannot guarantee or warrant the security of any information you transmit to us and you do so at your own risk.

Privacy Notice and Disclosures for California Residents

This section applies solely to the “personal information” (as defined in the California Consumer Privacy Act (“CCPA”) of users of the Site who reside in the State of California (“consumers” or “you”) and supplements the information contained in the rest of this policy.

Rights Provided By California Civil Code Section 1798.83

A California resident who has provided personal information to a business with whom he or she has established a business relationship for personal, family, or household purposes (a “California Customer”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. California Customers may request further information about our compliance with this law by contacting Modiv using the methods described at the end of this section under the heading “CCPA Requests.” Please note that we are only required to respond to two requests per California Customer each year under Code Section 1798.83.

Rights Under the California Consumer Privacy Act

We have included the following provisions of this policy to comply with the CCPA. This section of our privacy policy provides California residents with a comprehensive description of Modiv’s online and offline practices regarding the collection, use, disclosure, and sale of personal information and the rights of California consumers regarding their personal information under the CCPA. This section applies to all California residents (but not including legal entities, such as companies). The section will not apply, however, if Modiv does not collect any personal information about you or if all of the information we collect is exempt from the statute (for example, the CCPA does not protect information that is already protected by certain other privacy laws, and it does not protect information that is already publicly available).

YOU HAVE A “RIGHT TO KNOW” ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD

California residents have the right to request that Modiv disclose what personal information it collects, uses, discloses, and sells. This is called the “Right to Know.” Under the “Right to Know,” you can request a listing of the types of personal information we have collected about you, the sources of that information, how we use the information (e.g., our business or commercial purposes for collecting personal information), other individuals and business with whom we share personal information, and the specific pieces of personal information that we have collected about you.

Directly from the consumer	Examples of Information	Collected*	Source
A. Identifiers.	Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Yes	Directly from the consumer
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, medical information, or health insurance information.	Yes	Directly from the consumer
C. Protected classification characteristics under California or federal law.	Age, race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.	Yes	Directly from the consumer
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	Directly from the consumer
E. Biometric information.	Genetic, physiological, biological, or behavioral characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, or sleep, health, or exercise data.	No	N/A
F. Internet or other similar network activity.	Browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement.	Yes	Directly from the consumer
G. Geolocation data.	Physical location.	Yes	Directly from the consumer and through third parties.
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No	N/A
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes	Directly from the consumer
J. Education information that is not publicly available including personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).	Information directly related to a student that are maintained by an educational agency or institution or by a person acting for such agency or institution.	No	N/A
K. Inferences drawn from any of the above information.	Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No	N/A

* A response of “Yes” means that at least one piece of information that falls within this category has been collected. It does not mean that all of the example information provided above has been collected.

If you would like to make a request under this “Right to Know,” you may contact us by phone at 1-855-742-4862, by email at info@modiv.com . When you make a request under your “Right to Know,” you can expect the following:

Verification: We will verify your identity. You will need to provide us the following: (i) sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Confirmation: We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us using one of the methods described at the end of this section under the heading “CCPA Requests.”
Response: We will respond to your request within 45 days. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
In certain cases, a “Right to Know” request may be denied. For example, if we cannot verify your identity or if providing you the information could create an unreasonable risk to someone’s security (e.g., we do not want very sensitive information disclosed inappropriately), then we may deny your request. If this happens, we will explain why we denied it. If we deny a request, we will still try to provide you as much of the information as we can, but we will withhold the information subject to denial.

Modiv may collect the following categories of personal information from individuals. The business or commercial purposes of such collection includes: (i) advertising and marketing our products and services, including the personalization of such experiences, (ii) general support of our business, including account management, fraud prevention, and improving our websites, applications, products, and services, (iii) fulfilling certain legal obligations, as well as resolving disputes, enforcing our agreements, and defending against legal claims, and (iv) other business or commercial purposes, as described to you when collecting your personal information. If Modiv has done so within the past 12-months, this is indicated in the table below, along with the corresponding source:

“Personal information,” for purposes of this section regarding the rights of California residents, does not include information that is lawfully made available to the general public from federal, state, or local government records. It also does not include de-identified or aggregate consumer information.

YOU HAVE A “RIGHT TO REQUEST” THE DELETION OF PERSONAL INFORMATION ABOUT YOU

California consumers have a right to request the deletion of their personal information collected or maintained by Modiv. If you would like information about you to be deleted, you may contact us by using one of the methods described at the end of this section under the heading “CCPA Requests.” When you make a request for deletion, you can expect the following:

Verification: We will verify your identity. You will need to provide us the following: (i) sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Confirmation: We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us using one of the methods described at the end of this section under the heading “CCPA Requests.”
Response: We will respond to your request within 45 days. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
In certain cases, a request for deletion may be denied, for example, if we cannot verify your identity, the law requires that we maintain the information, or if retaining the information is necessary for us or our services provides to: (i) complete the transaction for which we collected the information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you, (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, (iii) debug products to identify and repair errors that impair existing intended functionality, (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law, (v) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.), (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent, (vii) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us, (viii) comply with a legal obligation, or (ix) make other internal and lawful uses of that information that are compatible with the context in which you provided it. If we deny your request, we will explain why we denied it and delete any other information that is not protected from deletion.

Sales of Personal Information

In the preceding 12 months, Modiv has not sold personal information of California consumers.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have a right not to receive discriminatory treatment by Modiv for exercising any of your privacy rights under the CCPA. Modiv will not discriminate against any California consumer because such person exercised any of the consumer’s rights under CCPA, including, but not limited to: (i) denying goods or services, (ii) charging different prices or rates for goods and services, including through the use of discounts or other benefits or imposing penalties, (iii) providing a different level or quality of goods or services, (iv) suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services. Modiv may, however, charge a different price or rate, or provide a different level or quality of goods or services, if that difference is related to the value provided to you by your data.

Authorized Agents

If you would like, you may designate an authorized agent to make a request under the CCPA on your behalf. We will deny requests from agents that do not submit proof of authorization from you. To verify that an authorized agent has authority to act for you, we may require a copy of a power of attorney or require that you provide the authorized agent with written permission and verify your own identity with us.

CCPA Requests

If you are a California resident and would like to make a request under the California Consumer Privacy Act, you may contact us by phone at 1-855-742-4862 emailing us at info@modiv.com or sending a letter to: RW Holdings Modiv REIT, Inc., 120 Newport Center Drive Newport Beach, CA 92660, Attn: Privacy Manager

Children

We do not solicit or knowingly collect personal information from anyone under the age of 13 or permit such persons to use our services. The Site is not intended for use by children. We do not intentionally gather personal information about individuals who are under the age of 13 except if provided by a parent or legal guardian as permitted by law. If a child has provided us with personal information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under the age of 13 not provided by a parent or guardian, please contact us at info@modiv.com . If we learn that we have inadvertently collected the personal information of a child under the age of 13, or equivalent minimum age depending on the jurisdiction, other than as permitted under this policy, we will take steps to delete the information as soon as possible.

Contacting the Web Site

If you have any questions about our privacy statement or our practices, please contact us at: info@modiv.com

Effective Date

This Privacy Policy was last updated on February 1, 2020.