VF Privacy Policy | ViaFina Sports

Privacy Policy

VIAFINA PRIVACY POLICY

Updated March 20, 2025

This Privacy Policy (“Policy”) describes how Viafina Sports, LLC. and its affiliates and subsidiaries (collectively, “Viafina Sports”, “we”, or “us”) collects, uses, and discloses, personal information about individuals who use our webWebsite (“Site”).

1. COLLECTION, USE, AND DISCLOSURE OF PERSONAL INFORMATION

In this Policy, “Personal Information” (a/k/a “Personal Data”) means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available as defined by applicable privacy legislation or is anonymized.

We collect Personal Information directly from you that you voluntarily share with us through the Website, indirectly from you through technology (e.g., your activity on the Website), and from Viafina Sports’ service providers, service professionals, third-parties, and other business partners.

Viafina Sports may process the following categories of Personal Information for the following purposes:

A. Non-Public Personal Information

Examples:**

Full name
Contact details (email address, mailing address, phone number)
User account information
Credit or debit card (or other financial information such as digital payment accounts)
Social security number
Customer records
Device identifier
IP address

More about payment card information: Although users may be able to submit payment information to pay for a service through the Website, we do not receive this information itself. Payment information is transmitted directly to our payment card processing vendor.

**Includes the information in Cal. Civil Code § 1798.80(e)

How and Why We Use Personal Information

Process and fulfill your services’ and products’ requests and orders, including scheduling, and canceling services, managing payments, and addressing complaints
Communicate with you and send you information about our services, Website, and promotions
Help us better understand your needs and preferences to provide consistent, personalized services and Website
Enhance your experience by tailoring our content or personalizing our Website and services
Help us evaluate, maintain, and improve our services and Website
Protect the security or integrity of our Website and our business, including by protecting against, detecting, or investigating malicious, deceptive, fraudulent, or illegal activity

How and Why We Disclose Personal Information

To service providers, and other third-parties, that assist with our business operations, including through processing payments, assisting with our customer service, communications delivery, background check, Website, analytics, marketing, and maintaining the security and stability of our Website and internal networks

To service providers, and other third-parties, that perform and fulfill your service requests and orders from the Site

If you are an employee, contractor, or other affiliate of any company participating on the Website as a service provider, we may disclose your Personal Information with that company.

B. Commercial Information

Examples:

Records of Website or merchandise purchased or services rendered, considered (including information provided as part of the Website)
Other purchasing consumer histories and tendencies (including ratings and reviews)

How and Why We Use Commercial Information

Process and fulfill your services’ and products’ requests and orders, including scheduling, and canceling services, managing payments, and addressing complaints
Communicate with you and send you information about our products, services, Website, and promotions
Help us better understand your preferences and enhance your experience by tailoring our content to provide consistent, personalized services, Website and products
Help us evaluate, maintain, and improve our services, products and Website
Protect the security or integrity of our Website, and our business, including by protecting against, detecting, or investigating malicious, deceptive, fraudulent, or illegal activity

How and Why We Disclose Commercial Information

To service providers, and other third-parties, that perform and fulfill your service requests and orders from the Site

If you are an employee, contractor, or other affiliate of any company participating on the Site as a service provider or merchandise seller, we may disclose your Personal Information with that company.

C. Inferences and Customer Profiles

Examples:

Information about your preferences
Information about your buying behaviors or tendencies
Information you provide voluntarily via surveys, ratings, or reviews included in our Website

How and Why we Use Inferences and Customer Profiles

Help us better understand your preferences and enhance your experience by tailoring our content to provide consistent, personalized Website
Help us evaluate, maintain, and improve our services, products and Website
Protect the security or integrity of our Website and our business, including by protecting against, detecting or investigating malicious, deceptive, fraudulent, or illegal activity

How and Why We Disclose Inferences and Customer Profiles

To service providers, and other third-parties, that assist with our business operations, including through processing payments, assisting with our customer service, communications delivery, background check Website, analytics, marketing, and maintaining the security and stability of our Site, and internal networks

D. Internet Activity Information

Examples:

Browsing and search history on our Website
Information about how you interact with our Website and ads
Mobile application usage information, if any

How and Why we Use Internet Activity Information

Help us better understand your preferences and enhance your experience by tailoring our content to provide consistent, personalized Website and products
Help us evaluate, maintain, and improve our products and Website
Protect the security or integrity of our Website and our business, including by protecting against, detecting, or investigating malicious, deceptive, fraudulent, or illegal activity

How and Why We Disclose Internet Activity Information

E. Geolocation Data

Example:

Approximate location inferred from IP address or interaction with geotargeted ads

How and Why We Use Geolocation Data

Help us better understand your preferences and enhance your experience by tailoring our content to provide consistent, personalized Website and products
Help us evaluate, maintain, and improve our products and Website
Protect the security or integrity of our Website and our business, including by protecting against, detecting, or investigating malicious, deceptive, fraudulent, or illegal activity

How and Why We Disclose Geolocation Data

If you are an employee, contractor, or other affiliate of any company participating on the Site as a service provider, we may disclose your Personal Information with that company.

F. Audio and Visual Information

Examples:

Recorded customer service calls and chats
Photos you give us

How and Why We Use Audio and Visual Information

Assist you with your service requests, including providing customer service to you
Help us evaluate, maintain, and improve our services, products and Site
Verify the identity of Viafina Sports’ service providers
Service providers requested through the Site may take photographs of completed Website and provide them to Viafina Sports
Protect the security or integrity of our Site and our business, including by protecting against, detecting, or investigating malicious, deceptive, fraudulent, or illegal activity

How and Why We Disclose Audio and Visual Information

To Service providers, and other third-parties, that assist with our business operations, including through processing payments, assisting with our customer service, communications delivery, background check, Website, analytics, marketing, and maintaining the security and stability of our Site, and internal networks

If you are an employee, contractor, or other affiliate of any company participating on the Site as a service provider, we may disclose your Personal Information with that company.

G. Professional or Employment-Related Information**

Examples:

Work experience
Skills
LinkedIn/Professional profiles
Any other information you provide regarding your background

**this section applies only to Viafina Sports’ service providers

How and Why We Use Professional or Employment-Related Information

Process your application for consideration to participate as a service provider, or other authorized user, on the Site

How and Why We Disclose Professional or Employment-Related Information

H. Legally Protected Characteristics

Examples:

Gender
Date of birth

How and Why We Use Legally Protected Characteristics

Process your application for consideration to participate as a service provider, athlete, or other authorized user, on the Site

How and Why We Disclose Legally Protected Characteristics

If you are an employee, contractor, or other affiliate of any company participating on the Site as a service provider, we may disclose your Personal Information with that company.

I. Sensitive Personal Information

Examples:

a consumer’s social security number, driver’s license, state identification card, or passport number
Precise geolocation of a consumer’s account log‐in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
the contents of a consumer’s mail, email, and text messages, unless the business is the intended recipient of the communication

Sensitive Personal Information is only used for legally permitted purposes.

How and Why We Use Sensitive Personal Information

Verify the identity of Viafina Sports’ service professionals
Protect the security or integrity of our Website and our business, including by protecting against, detecting, or investigating malicious, deceptive, fraudulent, or illegal activity

How and Why We Disclose Sensitive Personal Information

If you are an employee, contractor, or other affiliate of any company participating on the Site as a service provider, we may disclose your Personal Information with that company.

In addition to the uses and disclosures of Personal Information described in the section above, we may use and disclose any Personal Information as reasonably necessary to comply with regulatory and legal requirements, cooperate with and respond to law enforcement requests, or as otherwise required by applicable law, court order, or governmental regulations. We also use Personal Information we collect to maintain appropriate records for internal administrative purposes, to protect our rights and interests or those of others, to resolve any disputes, to enforce our policies, or to prevent harm. Any Personal Information we collect may be provided to our professional advisors, including accountants, auditors, consultants, and lawyers, when reasonably necessary for our professional advisors to give us appropriate advice. All Personal Information we collect may be transferred to another company in the event of a sale, merger, or other acquisition of some or all of our assets or business or as part of the negotiation or evaluation of such sale, merger, or other acquisition.

2. TRACKING TECHNOLOGIES AND COOKIES

We may collect information through technology to enhance our ability to serve you. When you access and use the Website, or contact us or our service providers, we and, in some cases, our service providers collect information about you or how you interact with the Website. We describe below a few of the methods we use to collect information through technology.

When you visit the Website, we may collect your Internet Protocol (IP) address. An IP address is often associated with the portal you used to enter the internet, like your internet service provider (ISP), company, association, or university. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. However, we may link the last IP address you used to access the Website to Personal Information you provide us. We may also collect a unique identifier for your computer, mobile device, or other device used to access the Website (“Device Identifier”). A Device Identifier is a number that is automatically assigned to the device you used to access the Website. We may link the Device Identifier to other information about your visit, such as what pages you viewed, and to Personal Information you provide us, such as your name. In addition to these methods, we may also collect information about how you interact with the Website through advertising partners and data enrichment tools.

a. Do We Use Cookies?

Cookies are small files that a website transfers to your device through a web browser that enables the website’s systems to recognize your device and to capture and remember certain information. You can find more information about cookies at: www.allaboutcookies.org. In general, our Website may use cookies: (1) where necessary to run our Website, (2) to optimize the functionality of our Website, including by personalizing content for you and remembering your preferences (e.g., your region), (3) for analytics purposes— for example, to help us understand how our Website is used, (4) to deliver advertisements relevant to you— for example, the cookies remember that you visited our Website after you leave. Sometimes they collect information about what pages of our Website you visited, and this information is shared with our advertising vendors, such as AppNexus, Google, Nanigans, Facebook, and Twitter.

Many advertisers and service providers that perform advertising-related functions for us participate in voluntary programs that provide tools to opt-out of such interest-based advertising such as the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding interest-based advertising for DAA members, visit https://youradchoices.com and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies also are members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/ . Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads (e.g., from other ad networks).

Our Website may use analytics technologies to support the operation and performance of our Website and to analyze your interactions and experiences with our Website, including the features you engage with, how you navigate, and your clicks, cursor movement, and scrolling activity, and general information about Site traffic data, performance, and related statistics. You may exercise choices regarding the use of cookies.

Rejecting Cookies Through Browser Settings: Most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. For more information on using browser settings to reject cookies, please visit www.allaboutcookies.org. You should note that rejecting cookies in your browser settings may mean that any preferences you set on the Website will be lost and that the Website may not work as well.

b. Web Beacons

We may include small graphic images or other web programming code, called web beacons (also known as “pixel tags”, “web bugs” or “clear GIFs”), on our Website and in our messages. The web beacons are minute graphics with a unique identifier. They are used to track the online movements of Website users. In contrast to cookies, which are stored in a user's computer hard drive, web beacons are embedded invisibly on webpages and are about the size of the period at the end of this sentence. Web beacons help us better manage content on the Website by informing us what content is effective, monitoring how users navigate the Website, counting users of the Website, and counting how many e-mails sent by us were actually opened.

c. Session Monitoring

Some of the technologies used on our Website may allow us and our service providers to monitor and analyze how visitors use our Website in order to better understand user behavior and improve our Website. When you interact with us online, information related to your browsing behavior may be collected by us and our service providers.

d. Your 'Do Not Track' Browser Setting

We do not support the Do Not Track (“DNT”) browser setting. DNT is a preference you can set in your browser's settings to let the Website you visit know that you do not want the Website collecting your Personal Information. We do track your online activities over time and across third-party Website or online Websites. For example, we may use web beacons to help us determine what links or advertisers brought you to our Website. We may also use third-party service providers to display advertisements to you on other Website based on your activities while on the Website.

e. Social Networking Website

If you login to the Website through a social networking site, such as Facebook, we may collect your Facebook authentication token and account identification number and use that information to provide you with access to your account on the Website.

3. INFORMATION FROM OR ABOUT OTHER PARTIES

a. Information You Provide About An External Party

Reviews and Ratings

The Website may display profiles of service professionals who participate on the Website. These profiles may include the service professional’s name, and ratings and reviews about the service professional provided by its’ customers. Service professional profiles may be visible to all users of the Website.

The Website may provide you with an opportunity to give ratings and reviews regarding service professionals or service requests. If you provide a rating or review about a service professional, we may post your first name, the initial of your last name, and the name of your neighborhood along with your rating or review on the service professional’s profile on the Website. In addition, service professionals may use your ratings and reviews, as well as this personal information about you, in their own marketing materials.

b. Information External Parties Provide About You

We may supplement the information we collect about you through the Website with records received from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you.

c. Information You Provide to a Third-Party / Third-Party Website

The Website may include links operated by third parties (“Third-Party Website”) and plug-ins (such as Twitter buttons) from Third-Party Websites. We do not control any Third-Party Website and are not responsible for any information they may collect. The information collection practices of Third-Party Websites are governed by those webWebsite' privacy policies. We recommend that you read the Third-Party Site's privacy policy if you choose to provide any personal information or click on a plug-in.

4. COMMUNICATION

SMS Text Messaging Disclosure

By using the Website, you expressly consent and agree to accept and receive communications from us, including via text message, calls, and push notifications to the cellular telephone number you provided to us. Standard text messaging charges applied by your cell phone carrier will apply to text messages we send. By consenting to being contacted by us, you understand and agree that you may receive communications, including marketing communications generated by automatic telephone dialing systems which will deliver prerecorded messages, sent by or on behalf of Viafina Sports, its affiliated companies and/or Users/Professionals, including but not limited to: operational communications concerning your account or use of the Website, updates concerning new and existing features on the Website, communications concerning promotions run by us, and news concerning Viafina Sports and industry developments.

You acknowledge that you are not required to consent to receive promotional messages as a condition of using the Website. If a contact number you have provided to us is no longer your number, you agree to notify us promptly that you can no longer be reached at that number. You represent that you have received, and are authorized to convey to us, the consent of any authorized users on your account to be contacted by us as described in this Section. You agree that all consents provided in this Section will survive cancellation of your account. You may opt-out of receiving promotional or marketing texts or calls from us at any time. You may opt-out of receiving all text (SMS) messages from us (including informational or transactional messages) by replying with the word “STOP” to a text message from us; however, you acknowledge that opting out of receiving all texts may impact your use of the Website.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

5. INFORMATION RETENTION

We keep the categories of personal information described above for as long as is necessary for the purposes described in this Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected; or
The personal information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case)
Where personal information is collected and used for more than one purpose, we will retain it until the purpose with the latest period expires.

6. TARGETED ADVERTISING, SALES, AND SHARING OF PERSONAL INFORMATION

Although we do not sell personal information in exchange for money, some of the ways in which we share personal information for targeted advertising may be considered “sales” or “sharing” under U.S. state privacy laws. Listed below are the categories of personal information we share for purposes of targeted/cross-context behavioral advertising or otherwise “sell” for non-monetary consideration:

Identifiers
Personal Records
Internet or other electronic network activity information
Geolocation Data (inferred from your IP address)
Inferences

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties for their own marketing reasons.

The types of third parties to which personal information is sold or shared are third-party advertisers and some analytics vendors. The purposes for which we sell/share this information include: showing you relevant ads while you browse the internet or use social media; marketing, advertising, certain types of analytics, or similar purposes. We do not have actual knowledge that we sell or share the personal information of consumers under 18 years of age. If you would like to opt out, please see the information below.

7. UNITED STATES PRIVACY RIGHTS

You have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request to us via email at admin@Viafinasports.com including the email address that you have used to transact with Viafina Sports. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. Any request you submit to us is subject to an identification process (“Verifiable Consumer Request”). We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected Personal Information. An authorized agent may submit a request on your behalf by emailing us at the email listed above. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

While some states have codified certain privacy rights for their citizens, Viafina Sports endeavors to use reasonable efforts to provide most of these rights to all of its users, regardless of their specific state residency. Please note these rights are subject to verification and there may be legal reasons we are unable to fulfill a request in your instance. In such instances, you will be advised and Viafina Sports has extended you a right of appeal. Below you will find a list of the privacy rights you may exercise with respect to your Personal Information Viafina Sports may have, including but not limited to disclosures for California residents under the California Consumer Protection Act (“the CCPA”):

Right to Delete: You may request we delete your Personal Information we have collected directly from you and are currently maintaining. Please note, however, that we may have a legal basis for retaining such Personal Information under applicable law, despite your request.

Right to Opt-Out: You have the right to opt out of targeted advertising, sales, and/or profiling. If you choose to use an opt-out browser signal, such as the Global Privacy Control, you will be opted out of cookie-based sales and shares. Please note that visiting our Website with an opt-out browser signal enabled will have the effect of opting you out of sales and sharing with respect to our Website. You will need to turn on the signal for each browser that you use.

Right to Opt Out of Targeted Advertising: You have the right to request that we stop disclosures of your Personal Information for targeted advertising via cookies and tracking technologies by adjusting your cookie preferences through the “Do Not Sell or Share My Personal Information” link in the footer of this page.

Right to Opt Out of Sales: We may process your Personal Information for targeted advertising and some of the ways that we disclose Personal Information may constitute a sale (as the term is defined in the applicable state privacy laws). You have the right to opt out of our Sales of your Personal Information.

Right to Opt Out of Profiling: You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not use Personal Information to conduct profiling.

Right to Know: You have the right to know what Personal Information Viafina Sports has about you, the categories of use, and the specific third-parties with whom your information may have been shared. You also have the right to obtain a transportable copy of your Personal Information. Your right to know request may be made no more than twice in a 12-month period. Your right to know request may encapsulate the following:

The categories of Personal Information we have collected about you
The categories of sources from which the Personal Information was collected
Our business or commercial purposes for collecting, selling, or sharing your Personal Information
The categories of third parties to which we disclosed your Personal Information
The specific third parties with whom your Personal Information may have been shared
The categories of Personal Information we sold or shared about you and the categories of third parties to which each category of Personal Information was sold or shared
The categories of Personal Information we disclosed about you for a business purpose and the categories of persons to which it was disclosed

Right to Request List of Third Parties: You have the right to request a list of Third Parties to which we disclosed your Personal Data, meaning a person, public corporation, or public body that is not a consumer, controller, processor, or affiliate of a controller or processor.

Right to Correct Personal Information: You may request we correct Personal Information that we maintain about you if you believe such Personal Information is inaccurate. Upon receipt of a verifiable request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the information as you direct.

Right to Limit Use and Disclosure of Your Sensitive Personal Information: In the event that we use sensitive Personal Information to infer characteristics about you, you may direct us to limit the use and disclosure of your sensitive Personal Information to uses and disclosures that are reasonably necessary to provide our goods and Website. We do not use or disclose sensitive Personal Information to infer characteristics, nor do we use or disclose sensitive Personal Information for other purposes not listed here.

Right to Non-Discrimination for the Exercise of Your Privacy Rights: If you choose to exercise any of your privacy options described herein you also have the right not to receive discriminatory treatment by us.

Right to Appeal: If you are unsatisfied with our actions related to the exercise of one of your privacy rights above, you may appeal our decision.

Notice of Financial Incentive

From time to time, we may offer discounts and promotions (“Programs”) that provide benefits to those who choose to participate. Participation requires you to provide some Personal Information, such as Identifiers (e.g., email addresses, phone numbers, and/or zip codes). The full terms and conditions of our Programs will be set forth where the opportunity to sign up is offered.

We have made a good faith estimate that the value of consumers’ Personal Information provided in connection with our Programs is equivalent to the relevant expenses related to the collection and retention of that Personal Information. By joining our Programs, you consent to any associated financial incentive. You have the right to withdraw from the financial incentive at any time by discontinuing our Programs in the manner provided.

Unless you specifically request, submission of a request to delete your Personal Information will not erase information required for you to continue to participate in our Programs. Should you wish to delete your Personal Information associated with our Programs (and thereby cancel your participation in our Program), please contact us at admin@Viafinasports.com. In addition, we may offer you financial incentives for the collection, sale and retention and use of your Personal Information as permitted by law. The material aspects of any financial incentive will be explained and described in its terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt-in to the Program and you can opt-out of each Program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable Program description and terms. We may add or change incentive Programs and/or their terms by posting notice on the Program descriptions and terms, so check them regularly.

California Shine the Light Law

The California Shine the Light law permits customers in California to request certain details about how their personal information is “shared” with third parties as defined in the Shine the Light law, and in some cases affiliates, if personal information is shared for those third parties’ or affiliates’ own direct marketing purposes. We share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our personal information sharing by contacting us at admin@Viafinasports.com. Please include “California Shine the Light Request” in the subject line and in the body of your message. Please note that “Shine the Light” rights are granted by different laws and must be exercised separately.

8. CHILDREN'S PRIVACY

We do not collect any information from anyone under 18 years of age. The Websites we offer are all directed to people who are at least 18 years old or older. If you are under the age of 18, you are not authorized to use the Website.

9. INTERNATIONAL VISITORS

Viafina Sports operates and is based in the United States. If you are using our Website outside the United States, please be aware that the information described in this Policy may be transferred to, or processed and stored in, the United States and other countries, which may employ greater or less restrictive data protection laws. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other countries may be different from the laws in your country. In all cases, we will take appropriate measures to protect your personal information in accordance with the standards described in this Policy.

10. SECURITY

The security and confidentiality of your Personal Information is important to us. We have implemented commercially reasonable technical, administrative, and physical security measures to protect your Personal Information from unauthorized access or disclosure and improper use. It is important for you to protect against unauthorized access to your account password and to your computer. Be sure to log out of your account or to close your browser after you have completed your visit to our Website. Please note that despite our reasonable efforts, no security measure is perfect or impenetrable, therefore we cannot guarantee the absolute security of your Personal Information.1

11. YOUR CHOICES

You may contact admin@Viafinasports.com to update, correct, or delete your Personal Information. You may also update, correct, and delete some of your Personal Information through your account on the Website.

You may opt out of

marketing emails by clicking the “unsubscribe” link at the bottom of emails we sen d, if any, or by sending an email to admin@Viafinasports.com .

12. CONTACT US

If you have any questions about this Policy, we'll do our best to answer them promptly. Here's how to contact us:

Email:

admin@Viafinasports.com

Mailing Address:

Viafina Sports, LLC

PO Box 585

Purchase, NY 10577

13. CHANGES TO THIS POLICY

If we change this Policy, we will post those changes on this page and will modify the “Last Updated” date at the top of this Policy. If we materially change this Policy in a way that affects how we use or disclose your Personal Information, we will notify you by prominently posting a notice of such changes before making them.