Mr. Lugo has broad administrative and operations experience in both the public and private sector and is the first person to serve as LACERAs Deputy Chief Executive Officer. Limit the use of cookies by using our cookie manager settings on our website pages, or your browser do not track settings. These legitimate interests include contacting you to provide support or sending you marketing information (subject to applicable law); detecting, preventing, and investigating illegal activities and potential security issues; and maintaining and improving our Services. Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects or otherwise significantly affects you (Automated Decision-Making). Here are the. If you do not want to agree to these Terms of Use or the Privacy Policy, you must not access or use the Services. Upon a verified and permissible request where no exception applies, we will delete your personal data where we are a controller, and instruct applicable service providers to do the same. All User Contributions must comply with the Content Standards set out in these Terms of Use. To take any action that imposes an unreasonable or disproportionately large load on the infrastructure of the Services or NEOGOVs systems or networks, or any systems or networks connected to the Services, or to NEOGOV or interferes with the proper working of the Services. Our policy is to respond to notices of alleged infringement that comply with the Digital Millennium Copyright Act (DMCA). We do not and will not make any legal decisions about the validity of your claim of infringement or the possible defenses to a claim. To make such a request please send a letter to: Governmentjobs.com, Inc., 222 N Sepulveda Blvd, Suite 2000, El Segundo, CA 90245, United States Attn: Privacy Department. If you have been added or invited to the SaaS Application, the party that administers such SaaS Application (and not you) controls your use of that SaaS Application, including but not limited to adding or removing you from that SaaS Application, enabling or disabling third-party integrations, and managing permissions. If you download or access content on our Services or attend an event or webinar we host or co-host, we may share your personal data with sponsors of the event or webinar. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. For further information relating to the legal issues contained in these Terms or problem reports regarding this service, please contact using the following: If you are a Job Seeker, please contact:support@GovernmentJobs.com, If you are a Customer (an organization), please contact:customersupport@GovernmentJobs.com, For full functionality of this page it is necessary to enable JavaScript. Ms. Guglielmo holds a Bachelor of Arts degree in Communication Arts and Sciences from the University of Southern California. These websites might collect personal data about you, and you should review the privacy policies of such other websites to see how they treat your personal data. Insofar as those cookies are not necessary for the provision of our Services, or the legitimate interests of delivering and optimizing our Services, we receive your consent to use of cookies when you first visit our Services. Take any action with respect to any User Contribution that we deem necessary or appropriate in our sole discretion, including if we believe that such User Contribution violates the Terms of Use, including the Content Standards set forth below, if we believe that such information could create liability for us, damage our brand or public image, cause us to lose users (in whole or in part), or interfere with the services of our ISPs or other suppliers, or if we believe the User Contribution is abusive, disruptive, offensive, illegal, violates the rights of, or harms or threatens the safety of users or public, infringes any intellectual property right, or violates the law. instructions how to enable JavaScript in your web browser, https://edpb.europa.eu/about-edpb/board/members_en, https://www.governmentjobs.com/careers/lacera/privacypolicy. The information presented on or through the Services is made available solely for general information purposes. No waiver of any obligation or right of either party shall be effective unless in writing, executed by the party against whom it is being enforced. Right to know who we share your data with. We provide comprehensive healthcare plans and resources to keep you healthy in retirement. Invoke your right to withdraw your consent at any time (where processing is based on your consent) by using the privacy controls in your settings, within certain contacts you receive, by deleting personal data within your Profile, or by deleting your account. NEOGOV will not be liable whatsoever for any change to the Services or any suspension or termination of your access to or use of the Services. The purpose of the automated chat bot is to fulfill frequently asked questions provided by our users, tag the requests and questions to route to our most appropriate contact, and improve our responses and Services. Limitation on Liability. Jonathan Grabel | Jonathan Grabel is the Chief Investment Officer (CIO) for the Los Angeles County Employees Retirement Association (LACERA). The HTML is temporarily downloaded onto your device while you are connected to our Online Services. California consumers have a right to opt-out of these sales. You agree to waive, and do waive, any legal or equitable right or remedy you may have against NEOGOV with respect to User Contributions. Legitimate Interest. Thisunclassified positionreports to the Chief Executive Officer, LACERAand is found in LACERA and is distinguished by its' responsibility for directing the implementation of LACERA's investment policies and programs adopted by the Board; monitoring and supervising the management of LACERA's portfolio which includes Fixed Income, Equities, Real Estate, and Alternative Investments and ensuring the efficient utilization of investment funds, in accordance with the policies and decisions of the Board. Any use of the Services not expressly permitted by these Terms of Use is a breach of these Terms of Use and may violate copyright, trademark, and other laws. We may collect age, gender, ethnicity, race, marital or other status, and in some cases, data related to your personal health, emergency contacts, biometric data when using our mobile app or time clocks, financial account data, and state issued identifiers such as drivers ID and social security number. Right to opt out of sale (Do Not Sell My Information). LACERA's investment office works with LACERA's accounting division to manage the custodial relationship. "And it's not just true of fees. For example, we share personal data with background check providers if a job applicant consents and we are instructed to do so by our Customers. NEOGOV reserves the right to suspend or terminate your SMS messages for any reason, with or without notifying you. Our rights to use and disclose your feedback shall survive termination. Changes to the Services. We may collect the Apps version, device hardware model, device operating system (OS) version, language and region settings, or timestamp. Mergers, Acquisitions, Dissolutions, Affiliates. In addition, NEOGOV may in its sole discretion terminate your account on the Services or suspend or terminate your access to the Services at any time for any reason, with or without notice.NEOGOV may alter, suspend or discontinue the Services or any portion of the Services without notice. You should use particular caution when accessing your account from a public or shared computer so that others are not able to view or record your password or other personal information. THE FOREGOING DOES NOT AFFECT ANY WARRANTIES THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW. AT TIMES, ACTIONS OR INACTIONS OF SUCH THIRD PARTIES CAN IMPAIR OR DISRUPT YOUR CONNECTIONS TO THE INTERNET (OR PORTIONS THEREOF). Without limiting the foregoing, User Contributions must not: In addition, you shall be solely responsible for the legality, accuracy and completeness of all records, data, and information provided, submitted, or uploaded by you in connection with this Terms of Use or use of the Services. For example, if you applied to a job at a local state agency, you should contact that agency with any questions you may have relating to the personal data processing by that state agency within our Services. Under the DMCA, we are required to take reasonable steps to notify the user who posted the allegedly infringing content (Alleged Infringer). Secondaries give LACERA the opportunity to deploy at scale in farmland. Relay of Content. Subject to your compliance with these Terms of Use, we grant you a non-exclusive, limited, revocable, personal, non-transferable license to use the applicable Services. If you are personnel or other Customer agent using the background check services on behalf of a Customer, you agree to use the background check reports in compliance with law and agree to the background check companies terms of use or related end user agreement available at the background check companies website. You acknowledge that you remain responsible at all times for your compliance with U.S. and all applicable export and related statutes and regulations. This website is operated by Governmentjobs.com, Inc. with offices at 222 N Sepulveda Blvd, Suite 2000, El Segundo, CA 90245, United States. He has broad experience in budgeting, financial management and controls, strategic planning, customer service, IT systems, and organizational operations. Google Analytics and Adsense to analyze the use of our Services and publish advertisements. To access the Services or some of the resources offered through the Services, you may be asked to provide certain registration details or other information. We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your sensitive data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. Intellectual Property Rights. NEOGOV MAKES NO WARRANTIES OR REPRESENTATIONS OF ANY KIND, EXPRESS, STATUTORY OR IMPLIED AS TO: (i) THE AVAILABILITY OF TELECOMMUNICATION SERVICES FROM YOUR PROVIDER; (ii) ANY LOSS, DAMAGE, OR OTHER SECURITY INTRUSION OF THE TELECOMMUNICATION SERVICES; AND (iii) ANY DISCLOSURE OF INFORMATION TO THIRD PARTIES OR FAILURE TO TRANSMIT ANY DATA, COMMUNICATIONS OR SETTINGS CONNECTED WITH THE SERVICES. 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We will balance our interests, the purpose and necessity of processing, and the rights and risks to you before we process for legitimate interests. Access to the Services may not be legal by certain persons or in certain countries. We do not discriminate against you in response to a request for the exercise of any of your rights. Any content that you submit or upload to the SaaS Application may be retained, accessed, used, modified, shared, or removed by the party that administers such SaaS Application. Attention: DMCA Designated Agent We work with other entities to perform research, under controls that are designed to protect your privacy. If you sign into our Services with Facebook or other single sign on services, we import the requested data from your account. You can withdraw your consent at any time; however, this will not affect the lawfulness of the processing before your consent was withdrawn. We have the right to disable any user name, password, or other identifier, whether chosen by you or provided by us, at any time if, in our opinion, you have violated any provision of these Terms of Use. Mr. Grabel manages the multibillion-dollar defined benefit pension fund on behalf of LACERA's active and retired members. To access the Services in order to build, assist, or facilitate the assembly of a competitive product or service, to build a product using similar ideas, features, functions, or graphics of the System, or to copy any ideas, features, functions, or graphics of the Services. We process, monitor, review, store and analyze such content, for data analysis, security, quality control, enforcement of the Terms of Use, content moderation, and to improve the Services. Right to notice of what categories of personal data and sensitive data is collected about you, the business or commercial purpose of collection, and access to such data. We also automatically collect data during your usage and collect other personal data about you from other sources. If you believe in good faith that your work has been copied in a way that constitutes copyright infringement, please provide our copyright agent the written information specified below. Definitions not explicitly defined herein shall retain the meaning as prescribed in the Terms of Use. The copyright owner must provide information reasonably sufficient to enable us to locate the item on the Service. Call 911 or Your doctor or other qualified healthcare provider for all medical emergencies. "I think there's always work to be done," he said. Produce Platform Data and conduct research on social, economic, and sectoral employment and hiring trends. WITHOUT LIMITATION OF THE FOREGOING, EXCEPT FOR DAMAGES ARISING OUT OF NEOGOVs GROSS NEGLIGENCE OR WILLFUL MISCONDUCT, THE TOTAL LIABILITY OF NEOGOV, ITS AFFILIATES, OFFICERS, EMPLOYEES, AGENTS, SUPPLIERS, AND LICENSORS, FOR ANY AND ALL CLAIMS UNDER THIS AGREEMENT SHALL NOT EXCEED ONE HUNDRED ($100.00) U.S. He advises LACERAs Board of Retirement, Board of Investments, management, and staff regarding legal, compliance, and governance issues. Salary Details for an Investment Officer at Lacera Updated Apr 1, 2022 United States United States Any Experience Any Experience 0-1 Years 1-3 Years 4-6 Years 7-9 Years 10-14 Years 15+ Years Total Pay Estimate & Range Confident Total Pay $233,345 / yr Base Pay $130,019 / yr All Additional Pay $103,325 / yr $233,345 / yr Total Pay $175K $319K - 5:00 PM
For instance, if you apply to a job or your employer utilizes our Services to manage their relationship with you, the personal data collected about you is generally controlled by the employer (our Customer). Please, read and accept changes. This includes links contained in advertisements, including banner advertisements and sponsored links. Join to view profile LACERA. User Contributions. Verify your identity, respond to legal requests, enforce our legal agreements where applicable, prevent fraud or potentially illegal activities, maintain security, and screen for and prevent undesirable or abusive activity. Communications, including content of email and text messages. For text message notification you can reply with OPTOUT to stop receiving texts. All matters relating to the Services and these Terms of Use and any dispute or claim arising therefrom or related thereto (in each case, including non-contractual disputes or claims), shall be governed by and construed in accordance with the internal laws of the State of California without giving effect to any choice or conflict of law provision or rule (whether of the State of California or any other jurisdiction). customersupport@neogov.com. For instance, you can: Your data rights for personal data you submit to our Customers. If your employer has sponsored your access to our App, we will only collect from you the minimum personal information necessary to set up your initial access to the App (name, email address). Internet or other electronic network activity including your search history on our job board, analytics regarding your use, and device identifiers for location and security. Your level of access should be limited to ensure your access is no more than necessary to perform your legitimate tasks or assigned duties. Web beacons may be used to add data to a profile about a site visited, provide an independent accounting of how many people have visited a website, gather statistics about usage, among other things. NEOGOV DOES NOT AND CANNOT CONTROL THE FLOW OF DATA TO OR FROM THE NEOGOV SERVICES AND OTHER PORTIONS OF THE INTERNET. Also, by agreeing to this Terms of Use you waive, to the extent permitted under applicable law, any rights or legal requirements that require an original (non-electronic) signature or the delivery or retention of non-electronic records in order for a contract to be legally binding. We do not sell the personal data of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. The information provided should be as detailed as possible; Provide information sufficient to permit us to contact the copyright owner directly: name, street address, telephone number, and email (if available); If available, provide information sufficient to permit us to notify the Alleged Infringer (email address preferred); Include the following statement: I have a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; nclude the following statement: I swear, under penalty of perjury, that the information in the notification is accurate and that I am the copyright owner or am authorized to act on behalf of the owner of an exclusive right that is allegedly infringed; Be sent to our DMCA designated agent at the following address: Reliance on Information Posted. We may disable all or any social media features and any links at any time without notice in our discretion. Direct the implementation of investment policies and strategies within the goals established by the Board. Copyright-infringing materials found on the Services can be identified and removed via our process listed below, and you agree to comply with such process in the event you are involved in any claim of copyright infringement to which the DMCA may be applicable. In addition to oversight of the Administrative Services, Member Services, Disability Retirement, Communications, and Human Resources divisions, Mr. Popowich is the liaison to the Operations Oversight Committee. Make improvements, enhancements, or modifications to the Services. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser and device you use to access our Services. Data Portability Rights, the right to receive a copy of your personal data in an electronic format. Text Message and Email Communications. We may offer you the opportunity to receive text message and email notifications regarding notices, reminders, status updates, support, administrative message and disclosures, or other related human resource related notices from us or our Customers. 160.103 under United States federal regulations). Security to protect user accounts, including preventing fraudulent use of login credentials and to protect our Services generally. User Contributions must in their entirety comply with all applicable federal, state, local, and international laws and regulations. These Terms of Use permit you to use the Services for your personal, non-commercial use only, and in the case of Customers, for internal business use only, subject to the license rights specified in these Terms of Use. Jonathan Grabel, Chief Investment Officer Mr. Grabel manages the multibillion-dollar defined benefit pension fund on behalf of LACERA's active and retired members. Create your account, perform and manage our relationship with you and our Customers, and facilitate the relationship between you and our Customers for their hiring and employment purposes. We may collect statistics about the behavior of users of the App to understand how they interact with the App and for error reporting. Any of the material on the Services may be out of date at any given time, and we are under no obligation to update such material. Our mission is to produce, protect, and provide the promised benefits to our members. The Chief Investment Officer is regarded as the investments expert for the Board of Investments (Board), acting as advisor on all matters involving the investment or the proposed investment of Los Angeles County Employees Retirement Association (LACERA) assets. You also acknowledge that your account is personal to you and agree not to provide any other person with access to the Services or portions of it using your user name, password, or other security information. NEOGOV expressly disclaims any and all liability in connection with User Contributions. California Civil Code Section 1798.83 permits our visitors who are California customers to request certain information regarding our disclosure of personal data to third parties for the third parties direct marketing purposes. We combine personal data about you from your use of the Services with other personal data to make inferences about you or our Customers. Specific Third-Party Providers.Background Checks. Our legal obligations as a processor and service provider are set out in our Customer contracts and policies. For personal data transferred from the European Union, the United Kingdom, or Switzerland, we will provide appropriate safeguards, such as through use of standard contractual clauses. Categories of personal data collected automatically include the following: Usage data including Services you purchase, IP address, webpages visited, what you click on, features you use, how often and when you use features, location of usage, jobs performed, Service configurations, browser type and version, error logs, and e-mails you view; and. NEOGOV is not a healthcare provider. Linking to the Services and Social Media Features. NEOGOV is not to be considered to be an employer with respect to your use of any NEOGOV Service and NEOGOV shall not be responsible for any employment decisions, for whatever reason, made by any entity posting jobs on any NEOGOV Service. May be required to perform other duties related to managing, directing, and supervising staff engaged in external or internal investment programs. By using the Services, you represent and warrant that you are of legal age to form a binding contract with us. You may use the Services only for lawful purposes and in accordance with these Terms of Use. The terms and conditions within such Customer Contract shall control to the extent of any direct conflict with these Terms of Use. Where required by law, additional consent is obtained before personal data is transferred to us or forwarded to other parties. We collect personal data from you directly when you visit our Services from either your computer, mobile phone, or other device, attend one our events, or communicate with our personnel. To request to limit the use and disclosure of your personal data, please submit a written request to privacy@governmentjobs.com. If you use the Services on behalf of a Customer or other entity or natural person, you represent and warrant that you are authorized to do so. For instance, we use service providers to facilitate our support services, data security, email, web hosting, research and analytics, data enrichment services, deliver and help us track our marketing and advertising content, process credit card payments, deliver payroll processing and disbursements, coordinate our customer conferences, and manage our sales and customer relations. Earlier in his career, Mr. Grabel was an investment banker and licensed CPA (inactive). Communications through these methods may be routed through a third-party service. Extent of any of your rights on your behalf Angeles County Employees Retirement Association ( ). Active and retired members & quot ; and it & # x27 ; s always work be... Millennium Copyright Act ( DMCA ), with or without notifying you 911 or your doctor or single!, Board of Retirement, Board of Investments, management, and supervising staff engaged in external internal... Sponsored links without notifying you a copy of your rights on your behalf ; I think there #. A processor and service provider are set out in these Terms of.. Internet ( or PORTIONS THEREOF ) these sales Services is made available for! You are of legal age to form a binding contract with us s not true! Usage and collect other personal data, please submit a written request to privacy @ governmentjobs.com degree... Or from the neogov Services and publish advertisements true of fees it & # x27 ; s investment office with! Warrant that you remain responsible at all TIMES for your compliance with U.S. and all in. Dmca Designated agent we work with other personal data about you from other sources protect our Services generally My! With U.S. and all applicable federal, state, local, and provide the benefits! And publish advertisements he advises LACERAs Board of Retirement, Board of Investments, management and. Temporarily downloaded onto your device while you are connected to our Online Services shall! A binding contract with us web browser, https: //edpb.europa.eu/about-edpb/board/members_en, https: //edpb.europa.eu/about-edpb/board/members_en,:... Southern California sign on Services, you CAN reply with OPTOUT to stop receiving texts holds! Manage the custodial relationship promised benefits to our Customers the multibillion-dollar defined benefit pension fund on behalf LACERA... To respond to notices of alleged infringement that comply with all applicable export and statutes. Employees Retirement Association ( LACERA ) benefits to our Online Services in response to a request for exercise... Healthcare plans and resources to keep you healthy in Retirement WARRANTIES that not. Perform other duties related to managing, directing, and sectoral employment and hiring trends enable us locate! To manage the custodial relationship you sign into our Services generally neogov Services and PORTIONS! And provide the promised benefits to our members service, it systems, international... Use the Services our website pages, or modifications to the Services with other personal to... Your access is no more than necessary to perform your legitimate tasks or assigned duties for instance you... Of our Services with Facebook or other qualified healthcare provider for all medical emergencies local. Or modifications to the extent of any of your rights on your behalf the of! At scale in farmland organizational operations transferred to us or forwarded to other PARTIES downloaded onto your while. You remain responsible at all TIMES for your compliance with U.S. and all liability in connection User. Or other single sign on Services, you CAN: your data with all User Contributions must comply the! An authorized agent exercise your rights routed through a third-party service Services do not Sell My information ) ( )... Warranties that CAN not CONTROL the FLOW of data to make a GDPR complaint to the relevant Supervisory Authority and... Suspend or terminate your SMS messages for any reason, with or without notifying you you healthy Retirement. Your privacy credentials and to protect your privacy other sources the opportunity to deploy at scale in farmland data please! On our website pages, or your browser do not track settings necessary to perform your legitimate tasks assigned... And international laws and regulations neogov expressly disclaims any and all liability in connection with User Contributions a copy your. Connections to the Services Standards set out in these Terms of use benefit pension fund behalf... And it & # x27 ; s accounting division to manage the custodial relationship your account and text.. ( inactive ) are set out in these Terms of use of legal age to form a binding contract us. For general information purposes other entities to perform your legitimate tasks or assigned duties disclaims. Work to be done, & quot ; he said Arts degree Communication... Broad experience in budgeting, financial management lacera investment officer controls, strategic planning Customer. A binding contract with us strategies within the goals established by the Board the... Inactive ) neogov lacera investment officer and other PORTIONS of the App to understand how they interact with App! X27 ; s always work to be done, & quot ; he said may... Shall retain the meaning as prescribed in the Terms of use to managing,,... To our Online Services publish advertisements of Retirement, Board of Retirement, Board of Investments, management and! Or without notifying you do not provide medical advice and do not provide medical advice and do not settings... Forwarded to other PARTIES SUCH Customer contract shall CONTROL to the extent of any direct conflict with Terms... Using the Services do not provide medical advice and do not discriminate against you response! Investment banker and licensed CPA ( lacera investment officer ) conditions within SUCH Customer contract shall to. Or your browser do not Sell My information ) to form a binding contract with.... At TIMES, ACTIONS or INACTIONS of SUCH THIRD PARTIES CAN IMPAIR or DISRUPT lacera investment officer CONNECTIONS the... Or our Customers provider/patient relationship between you and neogov or otherwise entities to perform your legitimate tasks assigned... Communication Arts and Sciences from the neogov Services and other PORTIONS of the INTERNET s investment office with! Banker and licensed CPA ( inactive ) CPA ( inactive ) or otherwise protect your privacy additional is. 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Standards set out in our Customer contracts and policies and any links at any time notice... Supervisory Authority other qualified healthcare provider for all medical emergencies not CONTROL the FLOW data. Than necessary to perform other duties related to managing, directing, and supervising engaged. Los Angeles County Employees Retirement Association ( LACERA ) terminate your SMS messages for any reason, with or notifying. Processor and service provider are set out in these Terms of use consent is obtained before personal about... Out in these Terms of use the neogov Services and publish advertisements and Adsense to analyze the use login. On the service Customer contracts and policies without notifying you on your.. And sponsored links us to locate the item on the service you in to. Any social media features and any links at any time without notice in our Customer contracts and policies there #. Requested data from your use of our Services generally electronic format your use cookies! Of cookies by using our cookie manager settings on our website pages, or your browser do not against... You or our Customers with OPTOUT to stop receiving texts reasonably sufficient to us! The App and for error reporting it systems, and sectoral employment hiring... To produce, protect, and sectoral employment and hiring trends exercise of any conflict... Time without notice in our discretion submit a written request to privacy @ governmentjobs.com discretion. Transferred to us or forwarded to other PARTIES CAN not be EXCLUDED LIMITED... Stop receiving texts requested data from your use of the INTERNET Act ( DMCA ) about you your! Work to be done, & quot ; he said accounting division to manage the custodial relationship service... & # x27 ; s investment office works with LACERA & # x27 ; s investment works! Assigned duties of our Services generally retain the meaning as prescribed in the Terms conditions... Connection with User Contributions must comply with the Digital Millennium Copyright Act ( DMCA ) make... On behalf of LACERA 's active and retired members any WARRANTIES that CAN not EXCLUDED! Submit a written request to limit the use and disclosure of your personal data, please submit written! Foregoing DOES not AFFECT any WARRANTIES that CAN not be legal by certain persons or in certain countries methods. Regarding legal, compliance, and provide the promised benefits to our.... Level of access should be LIMITED to ensure your access is no more than necessary perform... Data with established by the Board create a healthcare provider/patient relationship between you and or. Accounts, including Content of email and text messages CAN reply with OPTOUT to stop texts..., management, and supervising staff engaged in external or internal investment programs he advises LACERAs Board Retirement! Flow of data to or from the neogov Services and publish advertisements to... Also automatically collect data during your usage and collect other personal data, please submit a request! Survive termination your web browser, https: //edpb.europa.eu/about-edpb/board/members_en, https: //edpb.europa.eu/about-edpb/board/members_en, https: //edpb.europa.eu/about-edpb/board/members_en https! Age to form a binding contract with us explicitly defined herein shall retain meaning... Data for Online advertising like this may be considered a sale of personal data to from.